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Assessee has raised the ground that the Hon'ble DRP has erred in, law and facts, by upholding the stand of learned AO/TPO of not accepting the economic analysis undertaken by the Appellant in accordance with the provisions of the Act read with the Income Tax Rules, 1962 ("the Rules"), and conducting a fresh economic analysis for the determination of the ALP in connection with the impugned international transaction and holding that the Appellant's international transaction is not at arm's length.

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 - [2020] 82 ITR (TRIB) 467 (ITAT-BANGALORE)