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Transfer Pricing: Large Turnover Companies Not Comparable to Captive Units: ITAT Bangalore
Case Law Details
- Case Name
- Concur Technologies (India) Pvt. Ltd. Vs ACIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2021-22
- Courts
- All ITAT, ITAT Bangalore
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Concur Technologies (India) Pvt. Ltd. Vs ACIT (ITAT Bangalore)
Big Giants Out, Small Captive Wins – Working-Capital Adjustment Must, Interest on Receivables Only If Denied – Cherry-Picking of Comparables Not Allowed
Assessee, a captive service provider engaged in software development (SWD), IT enabled (ITeS) & marketing support services (MSS) to its AEs, contested a TP adjustment of ₹12.67 crore & interest addition on delayed receivables. The AO/TPO benchmarked each segment separately, using high-turnover companies like Infosys, TCS, Wipro & Cybage Software a...
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