Assessee company was engaged in distribution of satellite channels to local cable operators, multi system operators and Direct to Home (DTH) operators, therefore a company engaged in distribution of software product could be accepted as valid comparable. (AY. 2011-12)
Sony Pictures Networks India (P.) Ltd. v. DCIT (2020) 184 ITD 794 (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-A company engaged in distribution of software product could be accepted as valid comparable.