Dismissing the appeal of the revenue the Court held that, Company which out sourced its work cannot be accepted as comparable and also assesee rendering ITES services cannot be excluded merely because it did not make profit relevant assessment year. (AY. 2009 -10)
PCIT v. Nomura Structured Finance Service (P) Ltd. (2020) 268 Taxman 173 (Bom.)(HC)
S. 92C : Transfer pricing–Arm’s length price–Comparable-Employee cost filter-Company which out sourced its work cannot be accepted as comparable–ITES services–Cannot be excluded merely because it did not make profit relevant assessment year.