ALTERA DIGITAL HEALTH (INDIA) LLP (FORMERLY KNOWN AS ALLSCRIPTS (INDIA) LLP),VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

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ITA 359/AHD/2022Status: DisposedITAT Ahmedabad15 October 2025AY 2018-19Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that certain companies considered comparable by the TPO were functionally dissimilar and directed their exclusion. Consequently, the transfer pricing adjustment was deleted, and the appeal was allowed in part.

What were the facts?

The assessee challenged a transfer pricing adjustment and other additions made by the Assessing Officer. The primary dispute involved the arm's length price of software development services provided to associated enterprises.

What were the issues?

The key issues were the comparability of companies for transfer pricing analysis and the correctness of deductions, interest calculations, and deemed total income computation.

Which sections of the Income-tax Act were involved?

Section 92C,Section 10AA,Section 234A,Section 234C,Section 115JC,Section 270A

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, AHMEDABAD “D” BENCH

Before: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

आदेश की �ितिलिप अ�ेिषत / Copy of Order Forwarded to:- 1. Assessee 2. Revenue 3. Concerned CIT 4. CIT (A) 5. DR, ITAT, Ahmedabad 6. Guard file. By order/आदेश से,

उप/सहायक पंजीकार आयकर अपीलीय अिधकरण, अहमदाबाद

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