https://www.taxtmi.com/caselaws?id=238144 The ITAT Hyderabad partially allowed the assessee's appeal regarding exemption under section 10A and transfer pricing adjustments. It held that any expenditure excluded from export turnover must also be excluded from total turnover to maintain uniformity in calculating export turnover ratios. The tribunal directed the AO/TPO to exclude companies engaged in both product development and software services from comparables unless segmental data is available, emphasizing that inappropriate allocation of expenses between segments renders such comparables unreliable. Further, the AO/TPO was instructed to exclude comparables with related party transactions exceeding 15% of total revenue after verification. The decision followed precedents favoring the assessee and recognized the beneficial intent of section 10A. en-us Fri, 24 May 2013 00:00:00 +0530 Sat, 02 Aug 2025 12:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=238144 The ITAT Hyderabad partially allowed the assessee's appeal regarding exemption under section 10A and transfer pricing adjustments. It held that any expenditure excluded from export turnover must also be excluded from total turnover to maintain uniformity in calculating export turnover ratios. The tribunal directed the AO/TPO to exclude companies engaged in both product development and software services from comparables unless segmental data is available, emphasizing that inappropriate allocation of expenses between segments renders such comparables unreliable. Further, the AO/TPO was instructed to exclude comparables with related party transactions exceeding 15% of total revenue after verification. The decision followed precedents favoring the assessee and recognized the beneficial intent of section 10A. Case-Laws Income Tax Fri, 24 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=238144