| |
| The Tax Publishers2020 TaxPub(DT) 3878 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Where assessee was engaged in the business of software development, maintenance and IT enabled services, companies engaged in provision of Knowledge Process Outsourcing ('KPO') Services could not be selected for the purpose of benchmarking analysis.
|
Transfer pricing - Computation of ALP - Selection of comparables -
Assessee was engaged in the business of software development, maintenance and IT enabled services. TPO selected companies engaged in provision of Knowledge Process Outsourcing ('KPO') Services for the purpose of benchmarking analysis and accordingly made a transfer pricing adjustment.Held: Assessee provides information technology enabled services in the nature of back-office process outsourcing and inbounds and outbound voice based services (BPO), thus companies functionally dissimilar with that of assessee need to be deselected from final comparable list.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2014-15
INCOME TAX ACT, 1961
Section 195
 SUBSCRIBE FOR FULL CONTENT
|