Xoriant Solutions (P.) Ltd. v. ITO (2020] 183 ITD 180 (Mum.) (Trib.)

S. 92C : Transfer pricing-Arm’s length price-Comparable-Software development-Software education- Computer related activities like maintenance of website for its clients and creation of multimedia presentation-Product companies-Functionally not comparable-High turnover filter-Directed to be excluded.

Assessee was a company engaged in business of software development solely for its foreign Associates Enterprises (AEs). Tribunal held that companies which provided software education, Computer related activities like maintenance of website for its clients and creation of multimedia presentation, and Product companies are functionally not comparable. Similarly companies having high turnover filter are also directed to be excluded. (AY. 2010-11)