Tribunal partly allowing the appeal of the assessee, that the assessee restricted its argument in respect of 5 comparables raised out of 10 as they were covered by the order of a co-ordinate Bench of the Tribunal. The five comparables of which the assessee sought exclusion had been considered by a co-ordinate Bench of the Tribunal in a case where the assessee had been characterised to be rendering contract software development services to its associated enterprise. The functional profile of the assessee in the present appeal was the same and therefore the 5 comparables were to be excluded from the final list. (AY.2012-13).
IMS Health Analytics Services Pvt. Ltd. v. ACIT (2020) 84 ITR 277 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-Five companies to be excluded from final list of comparables. [S. 92CA]