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.

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)