https://www.taxtmi.com/caselaws?id=240749 The appellate tribunal set aside the DRP's orders and directed the TPO to determine the arm's length price afresh for international transactions of IT enabled back office services. Specific criteria were provided for determining comparables, emphasizing functional similarity, foreign exchange impacts, depreciation rate differences, and reliability of financial results. Exclusions of certain comparables were upheld based on objections raised by the assessee regarding extraordinary profits, turnover, fraud involvement, and functional dissimilarity. The tribunal partially allowed the appeal concerning the computation of deduction under section 10A, excluding certain charges from export turnover while considering them as normal business expenditures. en-us Thu, 31 Jan 2013 00:00:00 +0530 Wed, 11 Dec 2013 10:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=240749 The appellate tribunal set aside the DRP's orders and directed the TPO to determine the arm's length price afresh for international transactions of IT enabled back office services. Specific criteria were provided for determining comparables, emphasizing functional similarity, foreign exchange impacts, depreciation rate differences, and reliability of financial results. Exclusions of certain comparables were upheld based on objections raised by the assessee regarding extraordinary profits, turnover, fraud involvement, and functional dissimilarity. The tribunal partially allowed the appeal concerning the computation of deduction under section 10A, excluding certain charges from export turnover while considering them as normal business expenditures. Case-Laws Income Tax Thu, 31 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=240749