TIBCO Software India (P.) Ltd. v. DCIT
56 Taxmann.com 91Reported decision2015#9990 most cited
What is TIBCO Software India (P.) Ltd. v. DCIT authority for?
An uncontrolled transaction reflecting a loss is a normal incidence of business and should not be excluded as a comparable unless peculiar or abnormal circumstances are demonstrated. A company that is not consistently loss-making can be considered a comparable.
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judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2022.
Also referred to as
TIBCO Software India Pvt Ltd v DCIT · 56 taxmann.com 91 · comparable selection · uncontrolled transaction · business loss · consistent loss making company · transfer pricing