https://www.taxtmi.com/caselaws?id=236756 Transfer pricing comparability must be tested on turnover and functional similarity, so companies with markedly different turnover and functionally dissimilar operations are unsuitable comparables; the depreciation-adjustment question also required factual verification and was sent back. The section 10A computation had to preserve parity between export turnover and total turnover, so any item excluded from export turnover had to be excluded correspondingly from total turnover; the deduction was to be recomputed in the assessee's favour. Software expenditure required fresh examination on whether it was capital or revenue in nature, and the section 80JJAA claim was remanded for a factual determination of whether the employees satisfied the statutory description of workmen. en-us Thu, 28 Mar 2013 00:00:00 +0530 Sat, 07 Sep 2013 06:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236756 Transfer pricing comparability must be tested on turnover and functional similarity, so companies with markedly different turnover and functionally dissimilar operations are unsuitable comparables; the depreciation-adjustment question also required factual verification and was sent back. The section 10A computation had to preserve parity between export turnover and total turnover, so any item excluded from export turnover had to be excluded correspondingly from total turnover; the deduction was to be recomputed in the assessee's favour. Software expenditure required fresh examination on whether it was capital or revenue in nature, and the section 80JJAA claim was remanded for a factual determination of whether the employees satisfied the statutory description of workmen. Case-Laws Income Tax Thu, 28 Mar 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236756