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| The Tax Publishers2020 TaxPub(DT) 4772 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Acropetal Technologies Ltd. engaged in development of computer software products could not be considered as functionally comparable to assessee engaged in software development services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and failing of RPT filter
Assessee rendered software development services to its AE abroad. TPO considered Acropetal Technologies Limited as comparable to assessee's case.Held: Acropetal Technologies Ltd. engaged in development of computer software products could not be considered as functionally comparable to assessee's case.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 92C
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