Tribunal held that, software testing services company and a company rendering whole basket services . Company providing software services to its clients is not Comparables. ( AY.2014-15)
Fis Solutions (India) P. Ltd. v Dy. CIT (2020) 79 ITR 656 (Pune) (Trib)
S. 92C : Transfer pricing – Arm’s length price – Comparable- Software testing services company — Company rendering whole basket services — Company providing software services to its clients — Not Comparables.