Case Law Details
Case Name : Parametric Technology (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore)
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 differences in sc...
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