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The Tax PublishersIT(TP) A No. 150/Bang/2016
2021 TaxPub(DT) 0070 (Bang-Trib)INCOME TAX ACT, 1961
Section 92C
Persistent Systems Ltd. was engaged in development of software products along with software development services and since segmental details were not available, it could not be included in the list of comparables in case of pure software development services provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - No segmental details
Assessee rendered software development services to its AE abroad. TPO considered Persistent Systems Ltd. as comparable to assessee's case. Held: Persistent Systems Ltd. was engaged in development of software products along with software development services and since segmental details were not available, it could not be included in the list of comparables.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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