High Brand Value, Large-Scale Operations & Lack of Segmented Data are valid Ground for Exclusion in ALP Determination

Cadence Design Systems (India) Vs DCIT (Delhi High Court) The Delhi High Court recently issued a detailed judgment in the case of Cadence Design Systems (India) Pvt. Ltd. v. Deputy Commissioner of Income Tax (DCIT), addressing key transfer pricing issues. The court reviewed the inclusion of certain companies as comparables for determining the Arm’s Length Price (ALP) of Cadence India’s international transactions for the 2010-2011 assessment year. The ruling sheds light on criteria for comparability in transfer pricing cases, particularly concerning companies with high brand value or functi...