Tribunal held that the doctrine of commercial prudence invoked by assessee so much so it involved billing of software product purchased from parent company on cost to cost basis without any mark-up was to be demonstrated and proved with cogent evidence. Since complete details in said regard were not placed by assessee before authorities below, matter was to be remanded back for disposal afresh. (AY. 2010-11)
eBaotech India (P.) Ltd. V. Dy.CIT (2018) 196 TTJ 437 / 102 taxmann.com 169/ 67 ITR 90 (SN) (Mum.)(Trib.)
S. 92C : Transfer pricing-Arms’ length price–Business of developing, modifying and designing of computer software-Doctrine of commercial prudence invoked by assessee so much so it involved billing of software product purchased from parent company on cost to cost basis without any mark-up was to be demonstrated and proved with cogent evidence -Matter remanded.