Transfer Pricing: Large Turnover Companies Not Comparable to Captive Units: ITAT Bangalore

Concur Technologies (India) Pvt. Ltd. Vs ACIT (ITAT Bangalore)

Big Giants Out, Small Captive Wins – Working-Capital Adjustment Must, Interest on Receivables Only If Denied – Cherry-Picking of Comparables Not Allowed

Assessee, a captive service provider engaged in software development (SWD), IT enabled (ITeS) & marketing support services (MSS) to its AEs, contested a TP adjustment of ₹12.67 crore & interest addition on delayed receivables. The AO/TPO benchmarked each segment separately, using high-turnover companies like Infosys, TCS, Wipro &

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