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2022 (12) TMI 65 - AT - Income TaxTP Adjustment - Comparability - CTIL should be excluded from the comparable set - CTIL has subcontracted majority of its software development work to 3rd party vendors and has made significant payments to these vendors to the extent of 53-72% of total cost/27.85% of software development income - HELD THAT:- As it is well established principle that the company which does most of these activities through its own employees is not functionally comparable to a company which outsources majority of its work to third party vendors. In view of the above, we are of the considered view that CTIL should be excluded from the list of comparables, since CTIL is functionally different from that of the assessee company. Appeal of assessee allowed.
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