Agilent Technologies (International) Pvt. Ltd. v. ACIT (2022)97 ITR 326 (Delhi) (Trib)

S. 92C : Transfer pricing-Arm’s length price-Comparables-Software development and services and Information Technology–Outsourcing model of business–Company merged with two other companies, growth of revenue increased-Not to included in the list of comparables.

The Tribunal held that assessee was involved in in Information Technology enabled services different from companies in list of comparables. Hence, companies were to be excluded from the list of comparables. (AY.2008-09)