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| The Tax Publishers2019 TaxPub(DT) 7347 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Though Accel Transmatic Limited and was also engaged in sale of software products, however, segmental reporting was available in detail in Annual Report of this company, hence, it could not be excluded from set of comparables.
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Transfer pricing - Determination of ALP - Comparable also engaged in dissimilar activities - Segmental reporting available in detail
Assessee rendered software development services to its AE abroad. TPO considered Accel Transmatic Limited as comparable to assessee's case. Assessee challenged this on the ground that Accel Transmatic Limited. owned software products and was also engaged in sale of software products.Held: Though Accel Transmatic Limited and was also engaged in sale of software products, however, segmental reporting was available in detail in Annual Report of this company, hence, it could not be excluded from set of comparables.
REFERRED :
FAVOUR : Against the assessee.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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