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Product-Owning Companies Excluded from TP Analysis: Tribunal Refines Comparable Selection
Case Law Details
- Case Name
- SAP India Private Limited Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Bangalore
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SAP India Private Limited Vs DCIT (ITAT Bangalore)
ITAT Bangalore Grants Partial Relief by Excluding Own-Product/R&D-Heavy Comparables & Directs Correct Compucom Segment Margin, While Upholding TP Adjustment on Interest for AE Receivables
In SAP India Pvt Ltd’s appeal against the final assessment order u/s 143(3) r.w.s. 144C/144B, the Bangalore ITAT dealt with two primary issues- TP adjustment in the distribution segment & interest on overdue AE receivables. SAP India acts as a distributor of SAP software products while also providing consulting, implementation, ...
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