https://www.taxtmi.com/caselaws?id=213269 ITAT, Bangalore (AT) held that for determining ALP in software/ITES transactions loss-making comparables must be excluded and equally super-profit making companies should be excluded; comparables should be of similar size - here a turnover band of Rs.1 crore to Rs.200 crore was appropriate for an assessee with Rs.8.15 crore turnover. The revenue officer may collect contemporaneous market data from third parties without prior disclosure to the assessee, but the assessee must be given an opportunity to rebut material once relevance is established. Adjustments for under-utilisation of infrastructure must be afforded to the assessee as done for manpower. en-us Fri, 05 Aug 2011 00:00:00 +0530 Tue, 23 Jun 2026 15:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213269 ITAT, Bangalore (AT) held that for determining ALP in software/ITES transactions loss-making comparables must be excluded and equally super-profit making companies should be excluded; comparables should be of similar size - here a turnover band of Rs.1 crore to Rs.200 crore was appropriate for an assessee with Rs.8.15 crore turnover. The revenue officer may collect contemporaneous market data from third parties without prior disclosure to the assessee, but the assessee must be given an opportunity to rebut material once relevance is established. Adjustments for under-utilisation of infrastructure must be afforded to the assessee as done for manpower. Case-Laws Income Tax Fri, 05 Aug 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213269