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TP on Captive Software Services – Dissimilar Giants Excluded, Adjustment Removed
Case Law Details
- Case Name
- HighRadius Tecnologies Private Limited Vs DCIT (ITAT Hyderabad)
- 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 Hyderabad
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HighRadius Tecnologies Private Limited Vs DCIT (ITAT Hyderabad)
Transfer Pricing – Captive Software Development Services – Exclusion of Giant & Functionally Dissimilar Comparables – TP Adjustment Deleted
Tribunal held that Assessee is a low-risk captive SDS provider with no IP, no R&D & no market risk. TPO/DRP had wrongly included giant, diversified companies like L&T Infotech, Tata Elxsi, Infosys & Wipro. Tribunal found all these comparables to be functionally dissimilar due to huge turnover, ownership of IP/brands, diversified IT consulting, product...
Author Info
Title note states tribunal rejected tax payer’s plea where as tribunal deleted adjustment.!