Held that this a Government of India company and was not comparable with the assessee company, which was a purely private company as a government company was not driven by the profit motive alone. Thus, it was not comparable. The Assessing Officer/Transfer Pricing Officer was to exclude this company from the list of comparables in respect of the business support services segment. (AY. 2011-12)
Dy. CIT v. Bmc Software (India) Pvt. Ltd. (2022)96 ITR 18 (SN) (Pune) (Trib)
S. 92C : Transfer Pricing-Arm’s Length Price-Comparables-Government of India Company not Comparable with Assessee-Excluded from List of Comparables. [S.92CA]