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| The Tax Publishers2020 TaxPub(DT) 0216 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Flextronics Software Systems Ltd. (SEG) was having high turnover of about Rs. 457 crores. Further it was functionally different from assessee as it was engaged in end to end provider of communication products, services and solutions to network equipment providers, handset manufacturers, service providers and business process outsourcing sectors. Hence, there could be no comparability analysis.
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Transfer pricing - Determnation of ALP - Selection of comparables - High turnover and functional dissimilarity
Assessee rendered software development services to AE abroad. TPO considered Flextronics Software Systems Ltd. (SEG) as comparable to assessee's case. Held: Flextronics Software Systems Ltd. (SEG) was having high turnover of about Rs. 457 crores. Further it was functionally different from assessee as it was engaged in end to end provider of communication products, services and solutions to network equipment providers, handset manufacturers, service providers and business process outsourcing sectors. Hence, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2005-06
INCOME TAX ACT, 1961
Section 92C
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