https://www.taxtmi.com/caselaws?id=775091 ITAT Mumbai upheld CIT(A)'s decision on transfer pricing comparable selection criteria. The tribunal accepted exclusion of six companies (including Acropetal Technologies, E-Zest Solution, SankhyaInfotech, E-infochip, and Thirdware Solutions) as functionally dissimilar to the assessee based on detailed observations supported by documentary evidence. Regarding turnover filter, the tribunal endorsed CIT(A)'s application of 10 times turnover criterion (Rs. 380 crore cap) for arms' length price determination, acknowledging that higher turnover companies acquire significant intangibles affecting profitability comparisons in service industries. Seven companies (including Akshay Software Technologies, Celstream Technologies, Evoke Technologies, and Kireeti Soft Technologies) were included as valid comparables. The decision reinforced established ITAT precedent supporting reasonable turnover caps for transfer pricing benchmarking in service-oriented businesses. en-us Thu, 26 Jun 2025 00:00:00 +0530 Sat, 19 Jul 2025 08:25:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775091 ITAT Mumbai upheld CIT(A)'s decision on transfer pricing comparable selection criteria. The tribunal accepted exclusion of six companies (including Acropetal Technologies, E-Zest Solution, SankhyaInfotech, E-infochip, and Thirdware Solutions) as functionally dissimilar to the assessee based on detailed observations supported by documentary evidence. Regarding turnover filter, the tribunal endorsed CIT(A)'s application of 10 times turnover criterion (Rs. 380 crore cap) for arms' length price determination, acknowledging that higher turnover companies acquire significant intangibles affecting profitability comparisons in service industries. Seven companies (including Akshay Software Technologies, Celstream Technologies, Evoke Technologies, and Kireeti Soft Technologies) were included as valid comparables. The decision reinforced established ITAT precedent supporting reasonable turnover caps for transfer pricing benchmarking in service-oriented businesses. Case-Laws Income Tax Thu, 26 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775091