The Tax Publishers2021 TaxPub(DT) 0533 (Pune-Trib)

INCOME TAX ACT, 1961

Section 92C

Jindal Intellicom Private Ltd. was engaged in the call center business and did not earn any revenue from sale of products, therefore, it was duly comparable with that of assessee engaged in ITES.

Transfer pricing - Determination of ALP - Selection of comparables - Functional similarity

Assessee rendered IT-enabled services to its AE abroad. TPO considered Jindal Intellicom Private Ltd. as not comparable to assessee's case. Held: Jindal Intellicom Private Ltd. was engaged in the call center business and did not earn any revenue from sale of products. Accordingly, it was duly comparable with that of assessee.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2013-14


INCOME TAX ACT, 1961

Section 92C

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