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High Margin Giants Out, Wrong Margins Fixed – ITAT Slashes ₹83 Cr TP Hit on Schneider Electric
Case Law Details
- Case Name
- Schneider Electric Private Limited Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2021-22
- Courts
- All ITAT, ITAT Delhi
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Schneider Electric Private Limited Vs DCIT (ITAT Delhi)
Schneider Electric Pvt. Ltd. challenged transfer pricing adjustments of ₹83.69 crore made across three segments—Business Support Services, Contract R&D, and Intra-Group Services—along with a notional interest addition on AE receivables.
The ITAT found that the TPO had used wrong margins, ignored DRP directions, selected high-profit, functionally dissimilar comparables (Infosys, Wipro, Cybage, Tata Elxsi, etc.), and arbitrarily set ALP of intra-group services at Nil without examining evidence.
For Business Support Services, the T...
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