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TP Adjustments Reworked – ITAT Strikes Down Wrong Comparables, Demands Parity & Scientific Analysis
Case Law Details
- Case Name
- DRG Analytics and Insights Pvt. Ltd. Vs ACIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Bangalore
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DRG Analytics and Insights Pvt. Ltd. Vs ACIT (ITAT Bangalore)
TP Adjustments Reworked – ITAT Strikes Down Wrong Comparables, Demands Parity & Scientific Analysis
In the case of DRG Analytics and Insights Pvt. Ltd., the Bangalore ITAT dealt with multiple transfer pricing (TP) issues relating to comparables, ESOP costs, working capital adjustment, and interest on receivables.
On comparables, the Tribunal held that:
A company (Liquidhub Analytics Pvt. Ltd.) must be excluded since its Related Party Transactions (RPT) exceeded the 25% threshold adopted by the TPO himself.
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