Dismissing the appeal of the revenue the Court held that, a company operating at full fledged risk and performing services of application design, software engineering and technology cannot be compared with a company providing software support services. (AY. 2007-08)
PCIT v. ZTE Telecom India (P.) Ltd. (2019) 265 Taxman 70 (Mag.) (P& H)( HC)
S. 92C : Transfer pricing-Arms’ length price-Services of application design, software engineering and technology cannot be compared with a company providing software support services.