https://www.taxtmi.com/caselaws?id=462484 The ITAT Bangalore ruled on transfer pricing adjustments for an IT enabled services provider. The tribunal excluded three companies from comparable analysis: Harton Communications Ltd. due to lack of segmental revenue breakdown between software development and BPO services; Capgemini India Ltd. as it provides high-end specialized services unlike the assessee's low-end ITeS; and Infosys BPO Ltd. as it operates as a market leader with significant brand value, diverse service portfolio, and risk-bearing entrepreneur status unlike the captive service provider assessee. The tribunal also deleted additions related to common expense re-allocation, finding the AO's adjustment incorrect given the assessee's cost-plus markup model where charging expenses to STPI unit alone actually increased taxable income rather than reducing it. en-us Mon, 28 Feb 2022 00:00:00 +0530 Wed, 25 Jun 2025 19:01:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462484 The ITAT Bangalore ruled on transfer pricing adjustments for an IT enabled services provider. The tribunal excluded three companies from comparable analysis: Harton Communications Ltd. due to lack of segmental revenue breakdown between software development and BPO services; Capgemini India Ltd. as it provides high-end specialized services unlike the assessee's low-end ITeS; and Infosys BPO Ltd. as it operates as a market leader with significant brand value, diverse service portfolio, and risk-bearing entrepreneur status unlike the captive service provider assessee. The tribunal also deleted additions related to common expense re-allocation, finding the AO's adjustment incorrect given the assessee's cost-plus markup model where charging expenses to STPI unit alone actually increased taxable income rather than reducing it. Case-Laws Income Tax Mon, 28 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462484