IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No.2074/Bang/2024 Assessment Year: 2011-12 The Dy. Commissioner of Income Tax, Vs. Analog Devices India Pvt. Ltd., Circle – 1(1)(1), Salarpuria Nova, No.1, Bangalore. Varthur Road, Nagavarpalya, Old Madras Road, C.V Raman Nagar, Bangalore - 560 093.

PAN – AABCA 1873 F APPELLANT RESPONDENT CO No.25/Bang/2025 Assessment Year: 2011-12 Analog Devices India Pvt. Ltd., Vs. The Dy. Commissioner of Salarpuria Nova, No.1, Income Tax, Circle – 1(1)(1), Varthur Road, Nagavarpalya, Old Bangalore.

Madras Road, C.V Raman Nagar, Bangalore - 560 093.

PAN – AABCA 1873 F APPELLANT RESPONDENT Assessee by : Smt. Tanmayee Rajkumar & Shri Nirmal Mathew, Advocates Revenue by : Dr. Divya K.J, CIT (DR)

Date of hearing : 27.01.2026 Date of Pronouncement : 12.03.2026

O R D E R

PER WASEEM AHMED, ACCOUNTANT MEMBER:

The present appeal and the CO have been instituted by the Revenue and the assessee respectively against the order of the Ld. CIT- A passed u/s 250 of the Act dt. 30.08.2024 for AY 2011-12. In the memo of appeal, the Revenue has raised as many as 17 grounds of appeal challenging the deletion of the addition made on the Transfer pricing adjustment, we for the sake of brevity and convenience, are not inclined to reproduce the same here.

2. The issues raised by the revenue in ground Nos. 1, 5, 6, 7, 9, 11, 13, & 17 are general in nature and require no separate and independent adjudication. Therefore, we dismiss the same as infructuous.

3. The issues raised by the revenue in Grounds Nos. 2,3,4,8,10,12, 14, 15 and 16 are interconnected, pertain to the inclusion and exclusion of certain comparables by the Ld. CIT(A) for computing the ALP of the international transactions carried out with the AE by the assessee.

4. The brief facts of the case on hand are that the assessee, a private limited company, is engaged in providing SWD services and Marketing and Sales Support Activities (MSS) to its AEs. The assessee benchmarked its international transactions under SWD Segment & MSS Segment by adopting TNMM as the most appropriate method. The assessee worked out the PLI as OP/TC for both segments, which arrived at 10.89% and 10.12% respectively.

5. The assessee for the comparability analysis of SWD segment for determining the ALP selected 13 comparables detailed as under:

(i) Akshay Software Technologies Limited (ii) Bodhtree Consulting Limited (iii) Cat Technologies Limited (iv) Comp-U-Learn Tech India Limited (v) Helios & Matheson Information Technology Limited (vi) Maveric Software Limited (vii) Silverline Technologies Limited (viii) R S Software (India) Limited (ix) L G S Global Limited (x) Thinksoft Global Services Limited (xi) Quintegra Solutions Limited (xii) Compulink Systems Limited (Seg)

(xiii) Acropetal Technologies Limited (Seg)

5.1 However, the TPO during the assessment proceedings rejected 11 comparables out of 13 assessee’s comparables. The assessee’s comparables accepted by the TPO are detailed as under:

1. R S Software (India) Private Limited. 2. Acropetal Technologies Limited (Seg)

5.2 Thereafter, the TPO applied own filters and selected 13 comparables which included 2 assessee’s comparables. The final list of TPO’s comparables is detailed as under:

1. Acropetal Technology Ltd (Seg)

2. eZest Solution Ltd

3. E-infochips Ltd

4. Evoke Technologies Pvt Ltd 5. ICRA Techno Analytics Ltd

6. Infosys Ltd

7. Larsen and Toubro Infotech Ltd

8. Mindtree Ltd

9. Persistent Systems and Solutions Ltd

10. Persistent Systems Ltd 11. R S Software India Ltd

12. Sasken Communication Technology Ltd

13. Tata Elxsi Ltd

5.3 The average PLI/margin of the comparables companies was computed after providing working capital adjustment, at 21.56%. Accordingly, an upward TP adjustment was made by the TPO for Rs.

6,62,30,979/- only to the total income of the assessee.

6. Aggrieved by the order of the AO, the assessee preferred an appeal before the Ld. CIT(A).

7. B