The Tax Publishers2019 TaxPub(DT) 3186 (Del-Trib)

INCOME TAX ACT, 1961

Section 92C

Accentia Technologies engaged in providing healthcare and receivable management services involving medical transcription, medical coding, billing and receivables management could not be considered as functionally comparable with that of assessee engaged in IT enabled back office support services.

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

Assessee rendered IT Enabled back office support services to its AE abroad. TPO considered Accentia Technologies Ltd. As comparable to assessee's case. Held: Accentia Technologies engaged in providing healthcare and receivable management services involving medical transcription, medical coding, billing and receivables management could not be considered as functionally comparable with that of assessee.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2010-11


INCOME TAX ACT, 1961

Section 92C

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