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2018 (9) TMI 1943 - ITAT DELHITP Adjustment - comparability - functional dissimilarity - HELD THAT:- Assessee is engaged in provision of services of intermediate stage of design and development of software parts of Integrated Circuits [ICs] involving implementation, verification and maintenance services. The appellant company works as per the specification provided by the Group. It performs limited functions in the intermediate stage of the design and software development for the associated enterprises [AEs], thus companies functionally dissimilar with that of assessee need to be deselected from final list. Assessee is entitled for risk adjustment to the net margin of the comparables for bringing them at par with the taxpayer on supplying the complete data by the assessee.
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