ITAT Bangalore Applies Rs. 200 Crore Turnover Filter for TP Comparables

KBACE Technologies Pvt. Ltd. Vs DCIT (ITAT Bangalore) The appeal arose from the assessment order for Assessment Year 2013-14 pursuant to the directions of the Dispute Resolution Panel (DRP). The assessee, a wholly owned subsidiary of KBACE Technologies Inc., USA, was engaged in providing software development services to its associated enterprise. During the year, it entered into international transactions comprising software development service income and deferred receivables. The assessee benchmarked the transactions under the Transactional Net Margin Method (TNMM), whereas the Transfer Prici...