Assessee was engaged in providing software development services. therefore r a company engaged in providing IT enabled services and also into development of software products, was to be excluded from list of comparables. Similarly bigger sized company having turnover of Rs. 22,742 crore being in position to undertake more risks in business as compared to smaller size companies, was to be excluded from list of comparables. (AY. 2012-13)
Capgemini Technology Services India Ltd. v. DCIT (2020) 184 ITD 393 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable- Development of software products, was to be excluded from list of comparables-Bigger sized company having large turnover was to be excluded from the list of comaparbles.