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1 - 3 of 3 (0.15 seconds)Samsung Electronics Company Ltd., ... vs Dcit, Circle- 3(1)(2), New Delhi on 22 March, 2018
299.
We heard the rival submissions and
perused the material on record. We find from the
order of the Hon'ble DRP that in the case of ICRA
Techno Analytics Ltd., the Hon'ble DRP after
perusing the Annual Report had come to
conclusion that the service segment comprised of
software development, software consultancy,
engineering services, web development, web
hosting etc., for which no segment details were
available. The revenue had not led any evidence
on record controverting the above findings. Even
the Hon'ble coordinate bench in the case of DCIT
V. Electronics for Imaging India P. Ltd., [(2016) 70
taxmann.com 299 had held that this company is
not comparable with the software development
company in view of the fact that it is engaged in
the diversified activities. The relevant paragraph
is reproduced below:
The Income Tax Act, 1961
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