Held that the companies rendering software services cannot be compared with consulting business services. Inclusion of comparable N Ltd, subject to the availability of the accounts and passing of the filters is held to be valid. (AY. 2016-17)
Cowi India Pvt. Ltd. v. ITO (2021) 92 ITR 24 (SN) (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Selection of comparable-Consulting business-Companies rendering soft ware services cannot be comparable.