ITAT partially allowed the assessee's appeal regarding transfer...

ITAT partially allowed the assessee's appeal regarding transfer pricing adjustments. The Tribunal excluded seven companies (Tata Elexis Limited, E-Infochips Ltd, Larsen and Tourbo Infotech Limited, Infosys Ltd, Persistent Systems Limited, Infobeans Technologies Limited, and Thirdware Solutions Limited) from comparables following precedent, while retaining R S Software due to functional similarity. Mindtree Limited was excluded due to diverse service offerings and lack of segmental data. The Tribunal directed inclusion of Akshya Software and Sagar Soft as comparables but rejected Sankhya Infotech due to high R&D expenditure. Working capital adjustment was granted using average opening-closing balances. For interest on trade receivables, separate benchmarking was mandated at LIBOR plus 200 basis points with 60-day credit period. MAT credit was allowed subject to verification.

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