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2017 (5) TMI 1700 - ITAT BANGALORE
TP Adjustment - Comparable selection - functional dissimilarity - HELD THAT:- Companies functionally dissimilar cannot be compared with assessee-company which is engaged in IT enabled services.
We direct the AO/TPO to consider only profit margin of the software segment for the purpose of computing while arm's length price of the transaction.
RPT filer of 15% - TPO has applied RPT filter of 25%. The learned AR has not challenged the applicability of this filter. Therefore, we hold that Company failing to meet the filter set be excluded from the list of comparables.