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2018 (12) TMI 1071 - AT - Income TaxTPA - ALP determination - comparable selection - Held that:- Assessee is engaged in business of development of software solutions and other Information Technology Enabled Services. As been characterised as routine contract software/IT service provider working in a risk insulated environment in TP study, thus companies functionally dissimilar with that of assessee need to be deselected from final list. If a comparable is functionally same as that of the tested party then the same cannot be rejected merely on the ground that data for entire financial year is not available. If from the available data on record the results were financial year can be reasonably extrapolated, then the comparable cannot be excluded solely on this ground.
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