TP: Software developer cannot be compared with service provider

Transfer Pricing:  Companies in software development services not comparable with those in development of software products and services

Brief of the Case

ITAT Bangalore held in the case of GXS India Technology Center Pvt. Ltd. vs. ITO that a company which is engaged in development of software products and services cannot be compared to a company which is purely software development services provider. Also, company operates in the segments of software development services which

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