Tribunal held that where turnover of comparables companies was 10 times greater than that of assessee, these companies could not be considered as comparable companies, similarly a company engaged in provision of software solutions developed in-house, was to be excluded from list of comparables being functionally dissimilar. (AY. 2009-10)
Mformation Software Technologies (I) (P.) Ltd. v. ITO (2020) 182 ITD 78 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally different-Companies having turn over of 10 times greater cannot be considered as comparable companies.