ITAT allowed the taxpayer's transfer pricing challenges in part....
Transfer pricing appeals partly allowed; specified comparables excluded or remitted, some included; s.234A interest disallowed, recompute tax and refund
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Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
ITAT allowed the taxpayer's transfer pricing challenges in part. Two specified comparables were excluded from the final set on the basis of identical FAR findings in prior co-ordinate bench decisions; one specified reseller comparable was held comparable and included. Several other comparables engaged in trading were remitted to the AO/TPO for fresh verification against prescribed filters and segmental reporting. The Tribunal excluded multiple education-service comparables for functional dissimilarity, remitted others for verification of segmental revenues, and included one education comparable. Several software-development comparables were excluded, while a specific IT services comparable qualified for inclusion; additional IT comparables were directed to be examined against FAR for AYs 2020-21 and 2021-22. Working capital adjustments and proportionate adjustments were allowed; interest under s.234A was disallowed and the AO was directed to recompute tax/refund accordingly.
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