| |
| The Tax Publishers2021 TaxPub(DT) 0532 (Pune-Trib) INCOME TAX ACT, 1961
Section 92C
Kals Information Technology System Ltd. was engaged into development of software products as well as Software Development services and income from both of the streams was clubbed under the segment of 'Applications Software'. Since assessee was involved only in rendering Software Development services to its AEs, there could be no comparability analysis.
|
Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered software development services to its AE abroad. TPO considered Kals Information Technology System Ltd. as comparable to assessee's case. Held: Kals Information Technology System Ltd. was engaged into development of software products as well as Software Development services and income from both of the streams was clubbed under the segment of 'Applications Software'. Since assessee was involved only in rendering Software Development services to its AEs there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
 SUBSCRIBE FOR FULL CONTENT
|