Held that the company into sale of software products. In the absence of segmental details in the financial statements, it could not be treated as comparable to the assessee as it was not functionally similar. The Tribunal in an earlier case had excluded this company from comparables. Therefore, the Assessing Officer was to exclude this company from the list of comparables. (AY. 2014-15)
Qualcomm India Pvt. Ltd. v. Add. CIT (2023)102 ITR 556 (Delhi)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Selection of Comparable-Transactional net margin method-Functionally dissimilar-Software Services-Company engaged in diversified activities but segmental details relating to various segments not available in public domain and providing technical services-Cannot be taken as comparable.