Functionally Different Companies can’t be compared under transfer Pricing

Brief of the Case In the present case the Hon’ble Tribunal held that assessee can’t be compared with other companies when they are totally different in functions. Also, the Intellectual property Rights, Brand Value have to be seen while making comparisons under “Transfer Pricing”. Facts of the Case Assessee company is a private limited company which is a wholly owned subsidiary of Convergys Information management Group Inc., USA. The assessee company has been registered as a 100% EOU under the software technology parks of India (STPI) Scheme. It is engaged in providing software develop...