https://www.taxtmi.com/caselaws?id=395407 HC dismissed Revenue's appeal in a TP dispute involving a captive software development service provider. It upheld ITAT's exclusion of Infosys Ltd. as a comparable due to its huge intangibles, diversified functions, high-risk profile and significantly larger scale, rendering it functionally dissimilar. Wipro Technology Services Ltd. was rightly excluded because, post-acquisition, its services to Citi Group constituted a deemed international transaction under Section 92B(2), causing it to fail the 25% RPT filter and cease to be an uncontrolled comparable. Persistent Systems Ltd. and Thirdware Solutions Ltd. were also properly excluded owing to functional differences and absence of segmental data separating software services from product sales. en-us Mon, 18 May 2020 00:00:00 +0530 Tue, 16 Dec 2025 17:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395407 HC dismissed Revenue's appeal in a TP dispute involving a captive software development service provider. It upheld ITAT's exclusion of Infosys Ltd. as a comparable due to its huge intangibles, diversified functions, high-risk profile and significantly larger scale, rendering it functionally dissimilar. Wipro Technology Services Ltd. was rightly excluded because, post-acquisition, its services to Citi Group constituted a deemed international transaction under Section 92B(2), causing it to fail the 25% RPT filter and cease to be an uncontrolled comparable. Persistent Systems Ltd. and Thirdware Solutions Ltd. were also properly excluded owing to functional differences and absence of segmental data separating software services from product sales. Case-Laws Income Tax Mon, 18 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395407