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2019 (12) TMI 1279 - AT - Income Tax
TP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- Assessee is engaged in the business of software development and related services to its Associated Enterprises (AEs), SSIPL, wholly subsidiary of EMC Corporation, USA and the assessee was registered under SEZ on 14th August, 2008 for rendering IT and ITES to EMC Group of Companies and is compensated on mark up on cost basis for services provided and know how, copy rights etc. and other commercial and marketing services owned by EMC, thus companies functionally dissimilar with that of assessee need to be deselected from final list.