DCIT, CIRCLE-2(1)(2), BANGALORE vs. BROCADE COMMUNICATIONS SYSTEMS PVT. LTD., BANGALORE

ITA 167/BANG/2015Status: DisposedITAT Bangalore21 September 2026AY 2010-1111 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the DRP's decision to exclude specific comparable companies based on functional dissimilarity and lack of segmental information. The Tribunal found the DRP's reasoning to be well-supported and in line with established judicial precedents.

What were the facts?

The Revenue appealed against the DRP's order concerning transfer pricing adjustments for software development and marketing support services. The DRP had directed the exclusion of certain comparables identified by the TPO.

What were the issues?

Whether the DRP was justified in excluding certain companies as comparables for transfer pricing adjustments, and whether the TPO's selection of comparables was correct.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 143(1),Section 143(2),Section 142(1),Section 254(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI, VICE – & SHRI SOUNDARARAJAN K.

PER SHRI SOUNDARARAJAN K., JUDICIAL MEMBER:

This is an appeal filed by the Revenue challenging the order of the Ld.DRP dated 28/11/2014 in F.No: 30/DRP-BNG/2014-15. IT(TP)A No. 167/Bang/2015 M/s. Brocade Communications Systems Pvt. Ltd.

2.

The brief facts of the case are that the assessee is providing contract software research

The order continues below.

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