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Cherry Picking of Comparables Not Permissible – ITAT Clarifies TP Approach

Case Law Details

Case Name : Netradyne Technology India Pvt. Ltd. Vs. ITO (ITAT Bangalore)
Related Assessment Year : 2021-22
Courts : All ITAT ITAT Bangalore
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Netradyne Technology India Pvt. Ltd. Vs. ITO (ITAT Bangalore) Cherry Picking of Comparables Not Permissible – ITAT Clarifies TP Approach Assessee, a captive software development service provider for its US parent, reported international transactions of ₹39.35 crores in software development & ₹19.00 lakhs in software licence distribution. TPO rejected its TP study & adopted new comparables, selecting large companies like Infosys, Wipro, TCS, Mindtree, L&T Infotech, Tata Elxsi etc., despite Assessee’s small turnover. DRP confirmed. Before Tribunal, Assessee pressed grounds on...
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Name: CA Vijayakumar Shetty
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Company: Shetty & Co, Chartered Accountants, Mangalore
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Member Since: 17 Feb 2018 | Total Posts: 5443
CA Vijayakumar Shetty qualified in 1994 and in practice since then. Founding partner of Shetty & Co. He is a graduate from St Aloysius College, Mangalore . View Full Profile

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