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The ITAT upheld the TP adjustment for software development services to AE. L&T Infotech was considered comparable, rejecting appellant's argument. Persistent Systems Ltd's exclusion request was denied as it was part of the final comparables list. Imputing interest on receivables should use prevailing Indian rates or LIBOR with markup. The case law supports market-determined rates for benchmarking. Disallowance of employee PF contribution was upheld u/s 36(1)(va) u/s 2(24)(x) based on Checkmate Services case, stating belated remittance is not deductible even if paid before the return filing due date.
The ITAT upheld the TP adjustment for software development services to AE. L&T Infotech was considered comparable, rejecting appellant's argument. Persistent Systems Ltd's exclusion request was denied as it was part of the final comparables list. Imputing interest on receivables should use prevailing Indian rates or LIBOR with markup. The case law supports market-determined rates for benchmarking. Disallowance of employee PF contribution was upheld u/s 36(1)(va) u/s 2(24)(x) based on Checkmate Services case, stating belated remittance is not deductible even if paid before the return filing due date.
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