Dismissing the appeal of the revenue the Court held that exclusion or inclusion of RS Software would have no bearing, in view of said stand, appeal of assessee on issue of excluding RS Software as comparable, was to be dismissed as academic.
PCIT v. Avaya India (P.) Ltd (2025) 481 ITR 788/ 307 Taxman 179 (Delhi)(HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Exclusion or inclusion of RS Software would have no bearing-Issue of excluding RS Software as comparable would be academic.[S. 260A]
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