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| The Tax Publishers2020 TaxPub(DT) 4032 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Bodhtree Consulting Ltd. was engaged in developing Software Products owned substantial IP rights, etc. Accordingly, it could not be considered as functionally comparable to assessee (SWD service provider).
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered software development services to its AE abroad. TPO considered Bodhtree Consulting Limited as comparable to assessee's case. Held: Bodhtree Consulting Ltd. was engaged in developing Software Products owned substantial IP rights, etc. Accordingly, it could not be considered as functionally comparable to assessee's case.
Followed:Net Devices India Ltd. v. ITO (2015) 63 Taxmann.com 94 (Bang-Trib.).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2005-06
INCOME TAX ACT, 1961
Section 92C
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