The Tribunal held that a company deriving substantial revenue from software services, without segmental financial information, was functionally different from the assessee and could not be accepted as a comparable. Accordingly, the company was directed to be excluded from the final set of comparables. (AY. 2018-19).
MAN Energy Solutions India P. Ltd. v. Asst. CIT [2023] 149 taxmann.com 347 / (2025) 129 ITR 562 (Pune)(Trib.)
S. 92C : International transactions-Arm’s length price-Comparables-Functionally different company-Absence of segmental results-Comparable directed to be excluded.[S.92CA]
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