2020 (8) TMI 832 - AT - Income Tax

TP Adjustment - determination of Arm's Length Price [ALP] in respect of international transaction entered into by the assessee with its Associate Enterprise [AE] - comparable selection - HELD THAT:- The assessee provides software development [SWD] services to its AE. Rendering of SWD services by the assessee to its AE is an international transaction and that the income arising from the said international transaction has to be determined keeping in view the ALP as is required u/s. 92 of the Act. Thus companies functionally dissimilar with that of assessee need to be deselected.