It has been held by the Appellate Tribunal that the assessee was rendering software development services to its AE. Thus, a company engaged in KPO services was not acceptable as comparable with Assessee company. (AY.2011-12)
Microchip Technology (India) (P) Ltd v. ACIT (2021) 186 ITD 156 (Bang) (Trib)
S. 92C : Transfer pricing – Arms’ length price – A company engaged in KPO services is not comparable to software development service company.