Transfer PricingArticle·5 November 2026
Karnataka HC Upholds Comparable Exclusions and 15 percent RPT Filter
By J the App
Executive Summary
The Karnataka High Court dismissed the Revenue’s appeal concerning transfer pricing adjustments for AY 2006-07. It upheld the Tribunal’s exclusion of four companies as comparables, noting that the issue was covered by its decision in Logica Private Limited. The Court also held that the application of a 15% related-party transaction filter was covered by its decision in SAP Labs India. No substantial question of law arose for consideration.
Domain | DT | Transfer Pricing
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