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| The Tax Publishers2021 TaxPub(DT) 0096 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Being a product based company, was not strictly comparable to service company like assessee had related party transactions amounting to 34.68% of total turnover. Thus, it failed 25% RPT filter applied by TPO and hence, could not be taken as comparable.
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Transfer pricing - Determination of ALP - Selection of comparables - Failing of RPT filter
Assessee rendered software development services to its AE abroad. TPO considered Bodhtree Consulting Ltd. as comparable to assessee's case. Held: Being a product based company, was not strictly comparable to service company like assessee had related party transactions amounting to 34.68% of total turnover. Thus, it failed 25% RPT filter applied by TPO and hence, could not be taken as comparable.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2005-06
INCOME TAX ACT, 1961
Section 92C
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