ITAT Deletes ₹3.94 Crore TP Adjustment for Captive Software Provider

Altera Digital Health (India) LLP Vs DCIT (ITAT Ahmedabad) Functionally Different Comparables Removed – ITAT Deletes Entire TP Adjustment for Captive Software Service Provider Assessee, a captive software development service provider, earned a margin of 15.25% and benchmarked its international transactions using TNMM, selecting comparable margins between 5.98% and 7.32%. However, the TPO replaced comparables, introduced new companies, applied turnover filters and computed a median margin of 16.29%, leading to a TP adjustment of ₹3.94 crore, which the DRP upheld. Before the ITAT, the assess...