https://www.taxtmi.com/caselaws?id=234551 For s.10A deduction, the dominant issue was whether communication and related expenses attributable to delivery of software outside India, reduced from export turnover, must also be reduced from total turnover. Applying the HC ruling that parity between numerator and denominator must be maintained, the Tribunal directed reduction of the same amounts from both export turnover and total turnover while computing s.10A deduction. For transfer pricing of software development services, the dominant issue was selection of comparables and ALP. Applying turnover-based comparability (?1-200 crore range) and functional similarity, the Tribunal excluded multiple high-turnover entities and directed exclusion of one entity based on prior Tribunal precedent; it retained specified comparables, directed use of segmental margins for one comparable, and remanded reconsideration of one comparable, with adjustment only if the margin difference exceeded the statutory tolerance band. en-us Thu, 28 Mar 2013 00:00:00 +0530 Mon, 29 Dec 2025 16:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234551 For s.10A deduction, the dominant issue was whether communication and related expenses attributable to delivery of software outside India, reduced from export turnover, must also be reduced from total turnover. Applying the HC ruling that parity between numerator and denominator must be maintained, the Tribunal directed reduction of the same amounts from both export turnover and total turnover while computing s.10A deduction. For transfer pricing of software development services, the dominant issue was selection of comparables and ALP. Applying turnover-based comparability (?1-200 crore range) and functional similarity, the Tribunal excluded multiple high-turnover entities and directed exclusion of one entity based on prior Tribunal precedent; it retained specified comparables, directed use of segmental margins for one comparable, and remanded reconsideration of one comparable, with adjustment only if the margin difference exceeded the statutory tolerance band. Case-Laws Income Tax Thu, 28 Mar 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234551