November 20, 2025

Transfer Pricing: Large Turnover Companies Not Comparable to Captive Units – ITAT Bangalore

IntelME Verdict

Transfer Pricing

TL;DR

ITAT Bangalore ruled that large turnover companies like Infosys, TCS, and Wipro are not comparable to smaller captive units for transfer pricing, emphasizing functional similarity over size.

Analysis

This ruling by ITAT Bangalore highlights the importance of functional similarity over size in transfer pricing, impacting how Indian subsidiaries establish their transfer pricing positions. Tax professionals need to focus on selecting comparable companies based on functions rather than just turnover, to defend against potential arbitrary adjustments by tax authorities.

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