Indian Kanoon - Search engine for Indian Law

12. R. S. Software (India) Ltd.

12.1 The company was selected by the assessee in its transfer pricing study. The learned DRP retained the company in view of the fact that it was included by the DRP for assessment year 2012-13.

12.2 The learned counsel of the assessee submitted that company is engaged in on-site development of the software and cannot be compared with the assessee, which is an offside software developer. The Ld. counsel also referred to page No. 299 of the paper book and submitted the company was engaged in providing high-end technical services, including analytics services, testing services, dispute management, security management etc. He also submitted that company was engaged in significant R&D Activities in the areas of business intelligence, mobile payments, testing automation, cloud computing etc. According to the Ld. Counsel, the company being functionally dissimilar, cannot be compared with the assessee.