TP Adjustments Reworked – ITAT Strikes Down Wrong Comparables, Demands Parity & Scientific Analysis

DRG Analytics and Insights Pvt. Ltd. Vs ACIT (ITAT Bangalore) TP Adjustments Reworked – ITAT Strikes Down Wrong Comparables, Demands Parity & Scientific Analysis In the case of DRG Analytics and Insights Pvt. Ltd., the Bangalore ITAT dealt with multiple transfer pricing (TP) issues relating to comparables, ESOP costs, working capital adjustment, and interest on receivables. On comparables, the Tribunal held that: A company (Liquidhub Analytics Pvt. Ltd.) must be excluded since its Related Party Transactions (RPT) exceeded the 25% threshold adopted by the TPO himself. Once a filter is ap...