Held, that the functional profile of these comparables was different from that of the assessee-company. Both these entities were involved in software testing, verification and validation of software which fell in the domain of “software development” services. Besides this, separate segmental details pertaining to information technology enabled services or business process outsourcing activities were not available in their financial statements. Therefore, the Transfer Pricing Officer were to exclude both these comparables from the final list of comparables. Expenses on travel, boarding and lodging, etc. of its employees during outstation visits. Assessee should have marked up expenses by a profit-margin before making recoveries. Weighted average period of realization with respect to all invoices was only 20.52 days. Matter remanded. (AY.2010-11)
Dunnhumby It Services India P. Ltd. v. Dy. CIT (2021) 87 ITR 66 (SN) (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-Company whose audited financial data for previous year available in public domain not to be discarded merely because it has different financial year-Expenses on travel, boarding and lodging, etc. of its employees during outstation visits-Assessee should have marked up expenses by a profit-margin before making recoveries-Weighted average period of realization with respect to all invoices was only 20.52 days-Matter remanded.