Giant companies with high turnover & brand value cannot be comparables for small companies

Hydro BS India Private Limited Vs DCIT (ITAT Bangalore) Small Captive vs. Industry Giants- TP Adjustment Recast – Big Brand Comparable Out- Tribunal Removes Giant Companies from Comparable Bangalore Tribunal has excluded Infosys BPM Ltd. & Tech Mahindra Business Services Ltd. from the set of comparable, holding that giant companies with huge turnover & brand value cannot be compared to a small captive service provider rendering low-end ITES services. Assessee, a subsidiary of Hydro Group, provides back-office support services to its Associated Enterprise. It filed its return declarin...