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| The Tax Publishers2019 TaxPub(DT) 4713 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Accentia Technologies Ltd. was doing medical transcription work of a high-end variety, whereas assessee was provdiing back office support to its group companies and affiliates, in the field of reinsurance, which its affiliates were engaged in. This was entirely different from type of activities that Accentia Technologies Ltd. was into and hence, there could be no comparability analysis.
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Transfer pricing - Determination of ALp - Selection of comparables - Functional dissimilarity
Assessee rendered IT-enabled back office support services to its AE abroad. TPO cosndfiered Accentia Technologies Ltd. as comparable to assessee's case.Held: Accential Technologies Ltd. was doing medical transcription work of a high-end variety whereas assessee was provdiing back office support to its group companies and affiliates, in the field of reinsurance, which its affiliates were engaged in. This was entirely different from type of activities that Accentia Technologies Ltd. was into and hence, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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