comparables although they are secret
comparables for which no data was otherwise available, they are not functionally
comparable and also have supernormal operating margin ... expenses towards imports of software services, evidencing
outsourcing of software services unlike the appellant company. Hence, it
is functionally not comparable and cannot be treated
comparables although they are secret
comparables for which no data was otherwise available, they are not functionally
comparable and also have supernormal operating margin ... expenses towards imports of software services, evidencing
outsourcing of software services unlike the appellant company. Hence, it
is functionally not comparable and cannot be treated
same is functionally not comparable and the said comparable failing the related party
filter. We find that the said comparable has related party transactions ... same is functionally not comparable and the said comparable failing the
related party filter. We find that the said comparable has purchases with related party
treated as comparable.
6.1. He prayed for inclusion of one of the comparable chosen by the assessee viz
Akshay Software Technologies Ltd. He stated that ... functionally comparable .
6.2. He argued that with the aforesaid exclusions and inclusion of comparables with the
list of other comparables chosen
reject from the list of the comparable.
Since this comparable is sought to be excluded on the employee cost filter, no
opinion is given herein ... same is functionally not comparable and the said
comparable failing the related party filter. We find that the said comparable
has purchases with related party
accepted some of the
comparable companies chosen by the assessee as comparable with the Assessee and
rejected some of the comparable companies chosen ... range of
software products, software development and consulting services, IT enabled
service activities, IT infrastructure services and Business Process Outsourcing
software services, software products
accepted some of the
comparable companies chosen by the assessee as comparable with the Assessee and
rejected some of the comparable companies chosen ... range of
software products, software development and consulting services, IT enabled
service activities, IT infrastructure services and Business Process Outsourcing
software services, software products
that the assessee was engaged in execution of software
development and coding of software services (software services) outsourced to it
by its associated enterprise namely ... that the assessee was engaged in execution of software
development and coding of software services (software services) outsourced to it
by its associated enterprise namely
customizing the packaged software. The company also
explained that 30 to 40% of the product software (software developed)
would constitute packaged product and around ... customizing
the packaged software. The company also explained that 30 to 40% of the product
software (software developed) would constitute packaged product and around
applied by the Ld. TPO.
(c) Rejecting Akshay Software Technologies Ltd. as a comparable company in spite of
having Related Party Transaction ... that the assessee had provided software development services, such as, software
development services, software maintenance and repair services, quality testing services from
its three units
