ITO v. Interwoven Software Services (India) (P.) Ltd.

INCOME TAX ACT, 1961

--Transfer pricing--Determination of ALPSelection of comparables----Where assessee was rendering IT related services to its AE, ALP had to be determined by selecting proper comparable companies in terms of functionality, nature of services and brand value of the products. --Where assessee was rendering IT related services to its AE, ALP had to be determined by selecting proper comparable companies in terms of functionality, nature of services and brand value of the products.

Income Tax Act, 1961, Section 92C

Followed:Rampgreen Solutions (P.) Ltd. v. CIT 2015 234 Taxman 573.

REFERRED : Dy. CIT v. Electronics for Imaging India (P.) Ltd. (2016) 70 Taxmann.com 299 (Bang- Trib), Rampgreen Solutions (P.) Ltd. v. CIT 2015 377 ITR 533 (Del) and Novo Nordisk India (P.) Ltd. v. Dy. CIT 2015 63 Taxmann.com 351 (Bang-Trib).

FAVOUR : Partly in assessee's favour

A.Y. : 2010-11

IN THE ITAT, BANGALORE 'B' BENCH

S.K. YADAV, J.M. & A.K. GARODIA, A.M.

ITO v. Interwoven Software Services (India) (P.) Ltd.

IT(TP)Appeal Nos. 461 & 535 (Bang.) of 2015