Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Comparable selection for determining arm's length price (ALP) adjustment. Appeals limited to including or excluding certain uncontrolled entities as comparables suggested by appellant. Impugned order set aside to extent of rejecting appellant's challenge to inclusion of Avani Cincom Technologies Limited, Ishir Infotech Limited, Tata Elxsi Limited and Sasken Communication Technologies as comparables and excluding Akshay Software Technologies Limited as comparable for ALP determination. Matters remanded to Tribunal for fresh decision on appellant's objections regarding inclusion/exclusion of Ishir Infotech Ltd, Tata Elxsi Limited, Sasken Communication Technologies Limited and Akshay Software Technologies Limited for ALP adjustment determination, with contentions on merits reserved.
Comparable selection for determining arm's length price (ALP) adjustment. Appeals limited to including or excluding certain uncontrolled entities as comparables suggested by appellant. Impugned order set aside to extent of rejecting appellant's challenge to inclusion of Avani Cincom Technologies Limited, Ishir Infotech Limited, Tata Elxsi Limited and Sasken Communication Technologies as comparables and excluding Akshay Software Technologies Limited as comparable for ALP determination. Matters remanded to Tribunal for fresh decision on appellant's objections regarding inclusion/exclusion of Ishir Infotech Ltd, Tata Elxsi Limited, Sasken Communication Technologies Limited and Akshay Software Technologies Limited for ALP adjustment determination, with contentions on merits reserved.
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