Software development and services cannot be compared with activity of making animated film

M/s. Virage Logic International Vs JDIT (ITAT Delhi)

Tata Elexi Ltd.

i. Before the Ld. TPO, the assessee submitted that company is engaged in non-comparable services, which included IT enabled and software product services and, therefore, the company needs to be rejected. According to the Ld. TPO, the services of product design, innovation design engineering, visual computing labs are sub segment of software development industry and, therefore, he selected the company as comparable. The CIT(A), affirmed the action of the Ld. TPO.

ii. Be

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