Private Limited Circle2(1) Hyderabad Hyderabad PAN : AABCH8840F (अपीलाथ / Appellant) ( थ / Respondent) करदाता का ितिनिध / : Shri Ketan K.Ved, CA, AR Assessee Represented by राज का ितिनिध / : Ms.U.Mini Chandran,CITDR Department Represented by सुनवाई समा होने की ितिथ/ : 19.08.2025 Date of Conclusion of Hearing घोषणा की तारीख/Date of : 12.11.2025 Pronouncement ित रवीश सूद, जे .एम./PER RAVISH SOOD, J.M. The present appeal filed by the assessee company is directed against the order passed by the A.O under Section 143(3) r.w.s.144C(13) of the Income Tax Act, 1961 ("the Act") dated 2 ITA No.436/Hyd/2024 HighRadius Technologies Private Limited 25.02.2024, which in turn arises from the directions issued by the Dispute Resolution Panel1, Bengaluru (for short, "DRP") for the assessment year 202021. The assessee company has assailed the impugned order on the following grounds of appeal before us: "1. Erroneous transfer pricing adjustment of INR 10,58,23,162 in respect of international transaction of provision of software development and support services 1.1. The learned AO erred, on the facts and circumstances of the case and in law, in proposing a transfer pricing adjustment of INR 10.58,23,162/ to the income of the Appellant in relation to the international transection of provision of software development and support services ("SDS services"), vide Assessment Order under section 143(3) r.w 144C(13) read with section 144B of the Incometax Ac, 1961 ("he Ac" 1.2. The learned AO/Transfer Pricing Officer ("TPO") erred in law and in facts in rejecting the Appellant's transfer pricing documentation without any cogent reasons. 1.3 The learned AO/TPO erred in law and in facts by inappropriately rejecting some of the comparability filters adopted by the Appellant in its TP study report and applying additional filters and proceeded to undertake a fresh search for benchmarking the said international transaction of SOS services. 1.4 The learned AO/TPO erred in law and in facts in rejecting the following comparable companies accepted by the Appellant in its transfer pricing study report for benchmarking the said international transaction of provision of SDS services: •Inteq Software Pvt Ltd. •Yudiz Solutions Pvt. Ltd •R Systems International Ltd •Sasken Technologies Ltd. •Info Bears Technologies Ltd. 1.5 The learned AO erred in law and in facts in rejecting the following additional comparable companies proposed by the Appellant for 3 ITA No.436/Hyd/2024 HighRadius Technologies Private Limited benchmarking the said international transaction of provision of SDS services: •Indian Infotech Ltd. •Kireeti Soft Technologies •Hurix System Private Limited 1.6 The learned AO/TPO erred in law and in facts in selecting the following additional companies as comparable for benchmarking the said international transection of provision of SDS services: •Great Software Laboratory Pvt Ltd •Robosoft Technologies Ltd •Daffodil Software Pvt Ltd •Wipro Limited •Nihilent Limited •L&T Infotech Ltd •Virinchi Limited •CC VAK Software & Exports Ltd •XS CAD India Pvt Ltd. •Tata Elxsi Limited •Infosys Limited •Cybage Software Pvt Ltd •Harbinger Systems Pvt Ltd •Evoke Technologies Ltd •Mindtree Ltd 1.7 The learned AO/TPO erred in not applying the upper limit turnover filter while selecting comparable companies for benchmarking the said international transaction of provision of SDS services. 1.8 The learned AO/TPO erred in including companies as comparable having significant revenue/expenses from onsite activities while benchmarking the said international transaction of provision of SDS services. 1.9 The learned AO/TPO erred in computing the net operating margins of certain companies accepted as comparable for benchmarking the said international transaction of p