Transfer Pricing: Additions deleted in absence of comparable

Open Text Corporation India Private Limited vs. ACIT (ITAT Hyderabad) The assesse is engaged in providing software services. During the year under consideration the impugned segment of Arm’s Length Price (ALP) adjustment pertains to interest on receivables only. The Hon’ble ITAT deleted the transfer pricing adjustment on account of interest on receivables due to failure of revenue authorities to find out even a single comparable in assessee’s segment charging interest in uncontrolled market conditions. This is historical judgement wherein transfer pricing addition is deleted due to non a...