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.

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)