ITAT Bangalore rules large firms exceeding ₹200 crore turnover cannot benchmark smaller software companies
The Bangalore bench of the Income Tax Appellate Tribunal held that corporate entities with a turnover surpassing ₹200 crore are not appropriate comparables for a software firm generating ₹64 crore. This ruling provides crucial clarity on transfer pricing comparability standards for mid-sized technology enterprises.
Effective Not specified in the update
For professionals: The ITAT Bangalore ruled that companies with a turnover exceeding ₹200 crore cannot serve as valid comparables for benchmarking international transactions of a ₹64 crore software company · Professionals should review transfer pricing benchmarking studies to filter out large-scale enterprises that operate under vastly different economic realities and operational scales · Advising clients to challenge the inclusion of high-turnover giants prevents distorted profit-level indicators and unjustified tax adjustments during transfer pricing assessments
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