ITAT allowed the taxpayer's transfer pricing challenges in part....

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.