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| The Tax Publishers2020 TaxPub(DT) 5422 (Pune-Trib) INCOME TAX ACT, 1961
Section 92C
Cybermate Infotek Ltd. was engaged in rendering software development services as well but it had a mixed bag of financial statements comprising results not only of software development services but also software products dealt with by it. There was no information available on record to demonstrate revenue from software development services and corresponding operating costs, which part of its activity was analogous to the operations carried out by the assessee-company, therefore, Cybermate Infotek Limited could not be considered, on an entity level, as comparable to assessee (SWD service provider).
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Transfer pricing - Determination of ALP - Selection of comparables - Absence of segmental data
Assessee rendered software development services to its AE abroad. TPO considered Cybermate Infotek Ltd. as comparable to assessee's case. Held: Cybermate Infotek Ltd. was engaged in rendering software development services as well but it had a mixed bag of financial statements comprising results not only of software development services but also software products dealt with by it. There was no information available on record to demonstrate revenue from software development services and corresponding operating costs, which part of its activity was analogous to the operations carried out by the assessee-company. In the absence of such a vital information, Cybermate Infotek Limited could not be considered, on an entity level, as comparable to assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
INCOME TAX ACT, 1961
Section 144C(13)
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