No Fair ALP Without Upper Turnover Cap in TP Comparables ITAT Cochin

UST Global Technology Services (India) Private Limited Vs DCIT (ITAT Cochin) ITAT, Cochin: Directs AO/TPO to apply the upper turnover filter since it adopted a lower turnover limit of Rs. 1 crore Facts: The assessee, UST Global Technology Services (India) Pvt. Ltd., is a subsidiary of USIPL and engaged in providing IT services to its Associated Enterprises (AEs) as a captive service provider. For AY 2021–22, the assessee filed its return of income on 23.10.2022, declaring income of Rs. 11.83 crores. In Form 3CEB, it reported international transactions comprising provision of IT services amou...