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The Tax PublishersIT(TP)A Nos. 405, 474/Bang/2015
2020 TaxPub(DT) 3459 (Bang-Trib)INCOME TAX ACT, 1961
Section 92C
Infosys Ltd. having huge brand value and intangibles as well as bargaining power, could not be compared with captive software development services like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Huge brand value and intangibles as well as bargaining power
Assessee rendered software development services to its AE abroad. TPO considered Infosys Ltd. as comparable to assessee's case. Held: Infosys Ltd. having huge brand value and intangibles as well as bargaining power, could not be compared with captive software development services like assessee.
Followed:CSG Systems International (I) P. Ltd. v. DCIT, ITA No. 2026/Bang/2017, Order, dated 31-7-2016
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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