QUOTIENT TECHNOLOGY INDIA PRIVATE LIMITED,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

ITA 23/BANG/2026Status: DisposedITAT Bangalore10 September 2026AY 2022-2329 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal directed the Assessing Officer to recompute the margins of comparable companies and determine the arm's length price. Several comparable companies were ordered to be excluded or included based on specific filters like related party transactions and intangibles.

What were the facts?

The assessee's returned income was assessed at a higher amount due to an adjustment in the transfer price of international transactions. This adjustment was made by the Transfer Pricing Officer (TPO) and upheld by the Dispute Resolution Panel (DRP).

What were the issues?

The primary issues revolved around the validity of the transfer pricing adjustment, the selection and exclusion of comparable companies, and the application of various filters by the TPO and DRP.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 143(3),Section 144C,Section 153

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.

For Respondent: Smt. Divya K.J, CIT-DR

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT:

01.

This appeal by Quotient Technology India Private Limited [the Assessee/Appellant] relates to Assessment Year 2022-23 and is ITA 23/BANG/2026 QUOTIENT TECHNOLOGY INDIA PRIVATE LIMITED

directed against the assessment order dated 18 November 2025, passed under section 143(3) read with sections 144C (13) and 144B of the Income-tax Act, 19

The order continues below.

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