Transfer pricing adjustment in respect of the provision of software development services

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Last updated: 22 July 2021
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This case concerns a transfer pricing adjustment made by the tax authorities regarding software development services provided by a subsidiary to its associated enterprises. The assessee argued that its profit margin was at arm's length, using the TNM method and specific comparable companies. However, the Tax Officer (TPO) disagreed, selecting different comparables and proposing a higher adjustment, which was further enhanced by the Dispute Resolution Panel (DRP). The assessee is seeking the exclusion of certain comparables and the inclusion of others based on previous tribunal rulings.

Court :
ITAT Bangalore

Brief :
 The assessee has filed this appeal challenging the assessment order dated 7.7.2017 passed by the Assessing Officer for assessment year 2013-14 u/s 143(3) r.w.s 144C of the Act in pursuance of directions given by Ld. Dispute Resolution Panel (DRP).

Citation :
IT(TP)A No.1824/Bang/2017

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1 Year PLAN
1999
(Excl. of GST ₹359)

2 Years PLAN
3499
(Excl. of GST ₹629)

BEST VALUE
3 Years PLAN
4999
(Excl. of GST ₹899)

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