https://www.taxtmi.com/caselaws?id=219954 The ITAT Mumbai ruled on transfer pricing adjustments for R&D support services. The tribunal excluded Celestial Labs Ltd. from comparables as it primarily provides IT solutions rather than testing/analytical services. Biocon Ltd.'s subsidiaries were also excluded - Clinigene due to 38% related party transactions and Syngene due to different functional profiles and lack of segmental data. Diagnostic companies were excluded for having different service characteristics. The matter was remanded to TPO for risk adjustment analysis. Notional interest addition on receivables was deleted as the assessee had no borrowing costs and no agreement requiring interest charges. Network access charges were held to be revenue expenditure under section 37(1) as they facilitated day-to-day operations without creating enduring benefits. en-us Wed, 21 Nov 2012 00:00:00 +0530 Tue, 03 Jun 2025 16:49:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219954 The ITAT Mumbai ruled on transfer pricing adjustments for R&D support services. The tribunal excluded Celestial Labs Ltd. from comparables as it primarily provides IT solutions rather than testing/analytical services. Biocon Ltd.'s subsidiaries were also excluded - Clinigene due to 38% related party transactions and Syngene due to different functional profiles and lack of segmental data. Diagnostic companies were excluded for having different service characteristics. The matter was remanded to TPO for risk adjustment analysis. Notional interest addition on receivables was deleted as the assessee had no borrowing costs and no agreement requiring interest charges. Network access charges were held to be revenue expenditure under section 37(1) as they facilitated day-to-day operations without creating enduring benefits. Case-Laws Income Tax Wed, 21 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219954