IT/ILT : Where TPO made addition to assessee's ALP in respect of rendering software development services to its AE, in view of fact that one comparable was rendering said services by using its own IPRS in form of patents of software whereas assessee did not own any IPRS and, moreover, some other comparables were found improper on account of selling their own software products, impugned addition deserved to be set aside
No comments:
Post a Comment