Turnover Filter Applied to Exclude Mega-Scale ITeS Companies

DCIT Vs Zyme Solution Private Limited (ITAT Bangalore) TP Adjustment Partly Set Aside: High-Turnover Giants Out, Mechanical Exclusion Disapproved – ITAT Bangalore The Bangalore Bench of the ITAT, in DCIT vs. Zyme Solution Pvt. Ltd. along with Cross Objection by the Assessee (ITA No.1885/Bang/2024 & CO No.42/Bang/2024, AY 2013-14, order dated 19-12-2025), dealt with transfer-pricing adjustment relating to ITeS services rendered by the Assessee to its AE on a cost-plus 10% model. The Tribunal found fault with the mechanical approach adopted by the CIT(A) in excluding certain comparables me...