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The Tax PublishersIT (TP) A No. 3375/Bang/2018
2021 TaxPub(DT) 0174 (Bang-Trib)INCOME TAX ACT, 1961
Section 92C
Where assessee sought inclusion of a company (I2T2 India Limited) as a comparable company for the purpose of transfer pricing computations, following decision of Tribunal in case of LG Soft India P. Ltd., company (I2T2 India Limited) was held to be good comparable for a captive software development company such as assessee.
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Transfer pricing - Computation of ALP - Selection of comparables -
Assessee sought inclusion of a company (I2T2 India Limited) as a comparable company for the purpose of transfer pricing computations. Case of assessee was that said company was functionally comparable and passed all filters applied by TPO and was a good comparable for a captive software development service company. Held: In case of LG Soft India P. Ltd., it was held that comparable in question (I2T2 India Limited) was a good comparable for a captive software development company. Accordingly, following decision rendered by the co-ordinate bench in case of LG Soft India P. Ltd., TPO/AO was directed to include I2T2 India Ltd. as a comparable company.
Followed:LG Soft India P. Ltd. [IT (TP) A No. 3122/Bang/2016 dated 28-05-2019].
REFERRED :
FAVOUR : Matter remanded.
A.Y. : 2014-15
INCOME TAX ACT, 1961
Section 143(3) Section 144C
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