https://www.taxtmi.com/caselaws?id=767067 ITAT Hyderabad addressed transfer pricing comparable selection for software development services. The tribunal excluded Tata Elxsi Limited and Persistent Systems Limited due to functional dissimilarities, noting significant intangible assets and diversified activities respectively. Infosys Limited was excluded given its giant scale, brand value of USD 3414 million, and R&D expenditure exceeding 1000% of assessee's turnover. Mindtree Limited was excluded for onsite revenue exceeding 25% threshold. However, Larsen Toubro Infotech Limited and Infobeans Technologies Limited were retained as comparables since they were originally selected by assessee in TP documentation. Maveric Systems Limited and Harbinger Systems Private Limited were included despite R&D filter and database availability issues respectively. The appeal was partly allowed. en-us Thu, 06 Mar 2025 00:00:00 +0530 Mon, 10 Mar 2025 08:42:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767067 ITAT Hyderabad addressed transfer pricing comparable selection for software development services. The tribunal excluded Tata Elxsi Limited and Persistent Systems Limited due to functional dissimilarities, noting significant intangible assets and diversified activities respectively. Infosys Limited was excluded given its giant scale, brand value of USD 3414 million, and R&D expenditure exceeding 1000% of assessee's turnover. Mindtree Limited was excluded for onsite revenue exceeding 25% threshold. However, Larsen Toubro Infotech Limited and Infobeans Technologies Limited were retained as comparables since they were originally selected by assessee in TP documentation. Maveric Systems Limited and Harbinger Systems Private Limited were included despite R&D filter and database availability issues respectively. The appeal was partly allowed. Case-Laws Income Tax Thu, 06 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767067