Trident Microsystems India P. Ltd. v. Dy.CIT (2020) 83 ITR 449 (Bang.)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Comparable-Turnover filter-Turnover of more than Rs.200 crores was excluded-Market support services-Operating cost Matter remanded. [S. 92]

Tribunal remanded the entire issue was to be restored to the Assessing Officer/Transfer Pricing Officer for undertaking the exercise afresh selecting a fresh set of comparable companies in respect of the software research and development segment. Accordingly, the order passed by the Assessing Officer/Transfer Pricing Officer was to be set aside.  (AYs. 2011-12, 2013-14)