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2019 (11) TMI 1744 - ITAT HYDERABADTP Adjustment - comparable selection - HELD THAT:- Since the assessee company is primarily engaged in custom-built mobile applications and software support and maintenance related services to M/s. Kony Group of Companies, we are of the view that comparable company as functionally dissimilar with that of assessee need to be deselected. Since, the assessee had declared profit margin on cost @ 18.08% which is within the range of (+ / -) 3% of 20.31% as per the second proviso to section 92C(2) of the Act, we are of the considered view that TP Adjustment is not required in the case of the assessee towards assessee’s international transaction with respect to software development services.
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