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Companies with significantly higher turnover are not comparable: ITAT Bangalore
Case Law Details
- Case Name
- Parametric Technology (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore)
- 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 Bangalore
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Parametric Technology (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore)
ITAT: Companies with significantly higher turnover are not comparable and directed that interest on outstanding receivables be benchmarked at LIBOR plus 200 basis points
Summary: The Tribunal in Parametric Technology (India) Pvt. Ltd. vs DCIT held that transfer pricing adjustments in the software development (SWD) and software distribution (SDS) segments must be based on proper comparability analysis, emphasizing that companies with disproportionately high turnover cannot be compared with smaller entities due to ...
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