Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (12) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (12) TMI 1683 - AT - Income TaxTP adjustment - comparable selection for software development services - functinal similarity - need of segmental information - HELD THAT:- Infinite data systems private limited to be excluded on functional dissimilarity E info chips Bangalore Ltd company is primarily engaged in software development and IT enabled services which is considered as the only one reportable segments and therefore there is no segmental information available with respect to the software development activities as well as IT enabled services. In view of this the above comparable is required to be excluded from the comparability analysis of the software development service segment of the assessee. Infosys limited has huge brand value, huge turnover, and its "Finacle" Software is a leading product in banking industry. Therefore, making it functionally different and has significant R&D. Sonata software limited breaches RPT filter adopted by the Ld. transfer pricing officer - reexamine the claim of the assessee of Sonata Software limited not passing the filter of related party transactions Comparable for market support services - TSR Darashaw Ltd is primarily engaged in provision of share registry and related financial services and therefore, cannot be compared with the Assessee, a captive market support service provider. Global procurement consultants Ltd - perusing the functional profile of this comparable company, we are of the view that functions performed by this comparable company are comparable with the functions performed by the Assessee. Hence, we reject the argument of the Ld. Authorised Representative of the functional dissimilarity of this comparable.
|