Assessee engaged in providing Information Technology enabled services to associated enterprises while determining Arm’s length price, companies which are providing knowledge process outsourcing services, medical transcription services, development of infrastructure, high brand value are held to be not comparable. (AY.2012-13)
Evalueserve.Com Pvt. Ltd. v. Dy. CIT (2020) 77 ITR 97 (Delhi)(Trib.)
S. 92C : Transfer pricing–Arm’s length price-Comparable-Information Technology enabled services-Companies which are providing knowledge process outsourcing services, medical transcription services, development of infrastructure, high brand value are held to be not comparable. [S. 92CA]