ITAT Bangalore Accepts assessee’s plea to exclude comparables failing turnover filter

CAE Simulation Technologies Pvt. Ltd. Vs DCIT (ITAT Bangalore) In CAE Simulation Technologies Pvt. Ltd. vs DCIT (ITAT Bangalore) for AY 2021–22, the assessee, a captive software development service provider to its Canadian AE on a time-and-material basis, benchmarked its international transaction under TNMM (OP/TC) and claimed its margin fell within the arm’s-length range. The TPO rejected the assessee’s comparables, selected a new set, and proposed an upward TP adjustment of ₹1.15 crore, along with interest on outstanding receivables at LIBOR + 450 bps, treating delays as a deemed loa...