Tribunal held that the marketing support services same functions – can be treated as comparable, however companies deriving its income from manufacturing or trading and indenting services is not good Comparable for company rendering market support services. ( AY.2011-12)
Avaya India Pvt. Ltd. v. Dy. CIT (2020)78 ITR 84 ( Delhi ) (Trib)
S. 92C : Transfer pricing – Arm’s length price – Comparable Benchmarking of Transaction — Marketing support services same functions – Can be treated as comparable —Deriving its income from manufacturing or trading and indenting services — Not good Comparable for company rendering market support services.