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| The Tax Publishers2019 TaxPub(DT) 3322 (Pune-Trib) : (2020) 206 TTJ 0213 INCOME TAX ACT, 1961
Section 92C
Kals Information Technology Systems Ltd. was engaged in selling of software products which was different from activity undertaken by assessee namely, rendering of software development, services to AE, hence, there could be no comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered software development services to its AE abroad. TPO considered Kals Information Technology Systems Ltd. as comparable to assessee's case. Held: Kals Information Technology Systems Ltd. was engaged in selling of software products which was different from activity undertaken by assessee, namely, rendering of software development services to its AE, hence, there could be no comparability analysis.
Relied:CIT v. PTC Software (I) Pvt. Ltd. (2017) 395 ITR 176 (Bom) : 2016 TaxPub(DT) 4713 (Bom-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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