Aptara Technology (P) Ltd. (supra); CIT v. PTC Software (I) (P.) Ltd.
75 Taxmann.com 31High Court2016#6411 most cited
What is Aptara Technology (P) Ltd. (supra); CIT v. PTC Software (I) (P.) Ltd. authority for?
Data used for comparability analysis in transfer pricing must pertain to the same financial year as the international transactions of the tested party. Financial data from different financial years can lead to dissimilar business conditions, making companies from those periods invalid comparables.
18
judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2025.
Also referred to as
CIT v PTC Software · 75 taxmann.com 31 · Bombay High Court · transfer pricing · comparability analysis · financial year · international transactions · tested party · business conditions · comparable companies