https://www.taxtmi.com/caselaws?id=234231 The ITAT Bangalore directed the AO/TPO to reduce telecommunication and travel expenses from both export and total turnover for section 10A deduction, ensuring parity. The Tribunal restored the issue of the appropriate transfer pricing method (CPM/CUP vs. TNMM) for fresh consideration, referencing prior decisions. Several companies were excluded as comparables due to turnover or functional dissimilarity, while thirteen companies were retained. The AO/TPO was instructed to consider segmental margins for Mega soft Ltd and to verify whether professional fees paid by Ishir InfoTech relate to outsourced work, affecting comparability filters. Foreign exchange gains/losses must be treated consistently for the assessee and comparables. The working capital adjustment required reconciliation and was remitted for verification. Finally, if margin differentials exceed the 5% threshold under section 92C(2), appropriate transfer pricing adjustments are to be made. en-us Fri, 22 Feb 2013 00:00:00 +0530 Mon, 04 Aug 2025 16:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234231 The ITAT Bangalore directed the AO/TPO to reduce telecommunication and travel expenses from both export and total turnover for section 10A deduction, ensuring parity. The Tribunal restored the issue of the appropriate transfer pricing method (CPM/CUP vs. TNMM) for fresh consideration, referencing prior decisions. Several companies were excluded as comparables due to turnover or functional dissimilarity, while thirteen companies were retained. The AO/TPO was instructed to consider segmental margins for Mega soft Ltd and to verify whether professional fees paid by Ishir InfoTech relate to outsourced work, affecting comparability filters. Foreign exchange gains/losses must be treated consistently for the assessee and comparables. The working capital adjustment required reconciliation and was remitted for verification. Finally, if margin differentials exceed the 5% threshold under section 92C(2), appropriate transfer pricing adjustments are to be made. Case-Laws Income Tax Fri, 22 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234231