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 in transfer pricing, emphasizing functional similarity over size for benchmarking.
Analysis
The ruling by ITAT Bangalore sets a precedent in transfer pricing by prioritizing functional similarity over size when selecting comparables. This emphasizes the importance of accurate benchmarking, impacting how Indian subsidiaries approach transfer pricing defense strategies and potentially reducing arbitrary adjustments by tax authorities.
Source
TaxGuru Legal (India)↗Share: