Case Law Details
Case Name : HighRadius Tecnologies Private Limited Vs DCIT (ITAT Hyderabad)
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
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Title note states tribunal rejected tax payer’s plea where as tribunal deleted adjustment.!