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| The Tax Publishers2020 TaxPub(DT) 2997 (Del-Trib) : (2021) 085 ITR (Trib) 0360 INCOME TAX ACT, 1961
Section 92C
Assessee was engaged in provision of Software Development Services to its AE which was provided offsite whereas Acropetal Technologies Limited was providing onsite services and had booked expenditure on account of technical sub-contractors under the head 'onsite development' and failed employee/sales filter applied for benchmarking and hence, there could be no comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Different business model
Assessee rendered Software Development Services to its AE abroad. TPO considered M/s. Acropetal Technologies Ltd. (Seg.) as comparable to assessee's case. Held: Assessee was engaged in provision of Software Development Services to its AE which was provided offsite; on the other hand M/s. Acropetal Technologies Limited was providing onsite services and had booked expenditure on account of technical sub-contractors under the head 'onsite development'. It failed employee/sales filter applied for benchmarking. Accordingly, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 92C
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