Held that the assessee-company as well as L&T Ltd. are engaged in rendering software development services, the latter is comparable to the assessee, more so when the assessee itself has considered L&T as comparable in its TP study. TPO is directed to adopt appropriate rate of interest by considering the currency in which the outstanding receivable by the assessee and its AE. (AY. 2012-13)
Oakton Global Technology Services Centre (India) (P) Ltd. v ITO (2024) 230 TTJ 495 / 240 DTR 158 / 38 NYPTTJ 773 / 163 taxmann.com 769 (Hyd) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-comparables-There is no error in the reasons given by the TPO/DRP to include L&T in the final set of comparables-PLR-Interest on outstanding receivable-TPO is directed to adopt appropriate rate of interest by considering the currency in which the outstanding receivable by the assessee and its AE. [S.92B]