Product-Owning Companies Excluded from TP Analysis: Tribunal Refines Comparable Selection

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, & training se...