Held that when the assessee is providing software development service, company providing software development services as well as sale of software products are directed to be excluded from the final set of comparbles. (AY.2011-12)
Fiserv India Pvt. Ltd. v. ACIT (2021) 88 ITR 217 (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Software development service-Comparable-Companies providing software development services as well as sale of software products-Directed to exclude from the final set of comparbles. [S. 92CA(3)]