High Margin Giants Out, Wrong Margins Fixed – ITAT Slashes ₹83 Cr TP Hit on Schneider Electric

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...