Tribunal held that the revenue from information technology transactions services was less than 75 per cent. and consequently this company did not satisfy the filter of information technology revenue and was to be excluded and the entire revenue of P had been shown under the sale of software services and products segments and no separate segment had been given in respect of software services. The composite data of revenue as well as margins of this company pertaining to the sale of software services and products could not be considered as comparable with the software development services segment of the assessee. .( AY.2011-12)
Meritor Cvs India (P.) Ltd. v. ITO (2021)85 ITR 30 (SN)(Bang) (Trib)
S. 92C : Transfer pricing – Arm’s length price – Comparables — Company Having Less Than 75 Per Cent. of its revenue from Information Technology Services to be excluded – Company engaged in provision of routine software development services