Tribunal held that a giant risk-taking company was engaged in development and sale of software products and owned intangible assets was to be excluded from final list of comparables. Where assessee was engaged in providing Information Technology Enabled Services (ITES), a company earning revenue from outsourcing solutions to several clients and its service offerings span across multiple industries segment, was to be excluded from list of comparables. TPO was to be directed to allow working capital adjustment as per actuals. Some of the issues were remanded for re-examination. (AY. 2014-15)
Goldman Sachs Services (P.) Ltd. v. JCIT (2020) 182 ITD 189 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-Software development-Size and economies of scale/high risk companies-Functionally different-providing Information Technology Enabled Services (ITES) To be excluded from final list of comparables-Working capital adjustment was directed to be allowed on actual basis.