Shanti Prime Publication Pvt. Ltd.
Sec. 92CA of Income Tax Act, 1961—Transfer Pricing - Selection of Comparable- In the absence of segmental relevant data and particularly operating margins, composite data cannot be considered as comparable with the assessee for software development services segment- Since such entity level figures contain revenue from both software services and software products, as against the assessee only providing software services, this company cannot be treated as comparable- Company owning significant intangible and huge revenues from software products cannot be selected as comparable - NXP INDIA PVT. LTD. V/s DEPUTY CIT -  82 ITR (TRIB) 467 (ITAT-BANGALORE)