IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year: 2021-22 Parametric Technology (India) Pvt. Ltd., Vs. The Dy. Commissioner of Tower A, No.1 and 2, Income Tax, The Millenia, Murphy Road, Halasuru, Circle – 2(1)(2), Bengaluru – 560 008. Bengaluru.

PAN – AABCP 2629 J APPELLANT RESPONDENT Assessee by : Shri Darpan Kirpalani, CA Revenue by : Dr. Divya K.J, CIT (DR)

Date of hearing : 29.01.2026 Date of Pronouncement : 24.02.2026

O R D E R

PER WASEEM AHMED, ACCOUNTANT MEMBER:

The present appeal has been instituted by the assessee against the order of the Ld. AO/TPO u/s 143(3) r.w.s. 144C(13) of the Act dt.

23.10.2024 for the AY 2021-22

2. In the memo of appeal, the assessee has raised as many as 14 grounds of appeal challenging the addition made on the issue of Transfer pricing adjustments, we for the sake of brevity and convenience are not inclined to reproduce here.

2.1 At the outset, we note that the Ground No. 4 is general in nature and does not call for any specific adjudication. Accordingly, the same is dismissed as infructuous.

3. Ground Nos. 5, 6, 7 and 8 were not pressed by the assessee at the time of hearing and are accordingly dismissed as not pressed.

4. The issues raised by the assessee in Grounds Nos. 3, 9 to 11 are interconnected and pertain to fresh economic analysis conducted by the TPO and inclusion and exclusion of certain comparables by the TPO and by the learned DRP for computing the ALP of the international transactions carried out by the assessee with the AE.

5. The brief facts of the case on hand are that the assessee, a private limited company, is engaged in the business of software licenses through sale or subscription model and maintenance of software products of its ultimate holding company, PTC Inc. The assessee has divided its transactions in 2 segments mainly:

(i) Software Development Segment (SWD)

(ii) Software Distribution Segment (SDS)

5.1 The assessee benchmarked its transaction under SWD & SDS segment by adopting TNNM as most appropriate method and further PLI as OP/OC which arrived at 18.80% for SWD and 8.64% for SDS segment. The assessee for the comparability analysis under SWD segment selected 11 comparables.

5.2 However, the TPO during the assessment proceedings rejected 8 comparables out of 11 comparables selected by the assessee. The assessee’s comparables accepted by the TPO are detailed as under:

(i) CG-VAK Software and Exports Limited (ii) Sagarsoft (India) Limited (iii) Tata Elxsi Ltd – Software Development and Services

5.3 Thereafter, the TPO applied own filter and selected 18 additional comparable companies inclusive of 3 assessee’s comparables. Finally, the TPO selected 15 additional comparables and 3 assessee’s comparables. The final TPO’s comparables are detailed as under:

(i) Hurix Systems Private Limited (ii) Evoke Technologies Limited (iii) Indianic Infotech Limited (iv) Orion India Systems Private Limited (v) Mindtree Limited (vi) Sagarsoft (India) Limited (vii) Great Software Laboratory Private Limited (viii) Nihilent Limited (ix) Larsen & Toubro Infotech Limited (x) Wipro Limited (xi) Net4Nuts Limited (xii) Tata Elxsi Private Limited (xiii) Infosys Limited (xiv) CG-VAK Software & Exports Limited (xv) Aptus Software Labs Private Limited (xvi) Tata Consultancy Services Limited (xvii) Consilient Technologies Private Limited (xviii) Cybage Software Private Limited

5.4 The average PLI/margin of the comparables companies was computed at 25.09% with respect to SWD Segment. Accordingly, an upward TP adjustment was made by the TPO for Rs. 2,88,03,369/- only. 6. The aggrieved assessee preferred to file objections before the learned DRP.

6.1 Before the Ld. DRP, the assessee submitted that certain comparable companies were included by the TPO even though their turnover exceeded ₹200 crores for the captioned assessment year, whereas the assessee’s turnover from the Software Development (SWD)

segment w