Revenue cannot be aggregated for determining ALP of software development services for two different sectors

Brief of the Case

ITAT Hyderabad held In the case of M/s. OSI Systems Pvt. Ltd. vs. DCIT that it may be a fact that software development services is a very wide term and takes within its ambit, whole software development services. But all types of software development services cannot be clubbed together for comparability analysis, as in our view, it will not give an appropriate result. As in assessee’s case also software development services are for two different sectors i.e. security system as well a

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