PCIT v. Inductis (India) (P.) Ltd. (2020) 114 taxmann.com 319 (Delhi)(HC) Editorial : SLP of revenue is dismissed, PCIT v. Inductis India (P) Ltd. (2020) 270 Taxman 1 (SC)

S. 92C : Transfer pricing-Arm’s length price-Providing internet based medical health related services, a company rendering high end online software solutions, could not be accepted as comparable.

Dismissing the appeal of the revenue the High Court held that  concern provided high end online software solutions unlike the assessee, which provided internet based medical health related services. The real services, therefore, were entirely dissimilar hence could not be accepted as comparable.  (AY. 2011-12)