https://www.taxtmi.com/caselaws?id=311599 For benchmarking a captive software development service provider, comparables with product revenue, substantial intangibles, brand advantage, materially different functions, related-party linked transactions, or no reliable segmental data are not reliable. Infosys Ltd., Wipro Technology Services Ltd., e-Infochips Ltd., Sasken Communication Technologies Ltd., Persistent Systems Ltd. and Zylog Systems Ltd. were therefore excluded. CG-VAK Software & Exports Ltd. was included because it was not shown to be a persistent loss-maker and had profits in the relevant year; a company cannot be rejected merely on that ground. The transfer pricing set of comparables was accordingly revised and the arm's length price recomputed. en-us Tue, 21 Apr 2020 00:00:00 +0530 Thu, 04 Jan 2024 20:23:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311599 For benchmarking a captive software development service provider, comparables with product revenue, substantial intangibles, brand advantage, materially different functions, related-party linked transactions, or no reliable segmental data are not reliable. Infosys Ltd., Wipro Technology Services Ltd., e-Infochips Ltd., Sasken Communication Technologies Ltd., Persistent Systems Ltd. and Zylog Systems Ltd. were therefore excluded. CG-VAK Software & Exports Ltd. was included because it was not shown to be a persistent loss-maker and had profits in the relevant year; a company cannot be rejected merely on that ground. The transfer pricing set of comparables was accordingly revised and the arm's length price recomputed. Case-Laws Income Tax Tue, 21 Apr 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311599