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Transfer PricingArticle·10 October 2026

Karnataka HC says Turnover Matters in Selecting Transfer Pricing Comparables

By J the App

Executive Summary

The Revenue challenged the exclusion of certain software companies as comparables in determining the arm's length price. Applying the Karnataka High Court's decision in SAP Labs India, the Court affirmed the rationality of a ₹200 crore upper turnover filter and held that the substantial question of law did not arise in the appeal. The Revenue's appeal was dismissed.

Domain | DT | Transfer Pricing

The Position

The Revenue ...

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