Katerra Technology Services LLP v. ACIT (2024)113 ITR 576 (Pune)(Trib)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of ccomparables-Company functionally dissimilar from assessee-company is to be excluded from final set of comparables.

Held that the company Domex e. Data P. Ltd  was functionally dissimilar from the assessee-company. Therefore, the Assessing Officer and the Transfer Pricing Officer were to exclude Domex e. Data P. Ltd    from the final set of comparables. Domex e. Data P. Ltd     having been excluded while benchmarking of the information technology enabled services segment from the final list of comparables in the case of the assessee, all other transfer pricing grounds raised in this appeal becomes academic. (AY.2018-19)

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