https://www.taxtmi.com/caselaws?id=243714 The Tribunal partly allowed the assessee's appeal by directing the AO/TPO to recompute the Arm's Length Price (ALP) in accordance with its directions. The Tribunal disagreed with the disallowance of communication and circuit charges under Section 40(a)(ia) of the Income Tax Act, stating they were not fees for technical services. Certain companies were excluded as comparables for Transfer Pricing Analysis due to functional dissimilarity and other reasons. Adjustment for differences in depreciation rates was remitted for fresh consideration, and pre-operative expenses were directed to be excluded from operating costs for ALP computation. en-us Wed, 05 Feb 2014 00:00:00 +0530 Sat, 08 Feb 2014 12:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243714 The Tribunal partly allowed the assessee's appeal by directing the AO/TPO to recompute the Arm's Length Price (ALP) in accordance with its directions. The Tribunal disagreed with the disallowance of communication and circuit charges under Section 40(a)(ia) of the Income Tax Act, stating they were not fees for technical services. Certain companies were excluded as comparables for Transfer Pricing Analysis due to functional dissimilarity and other reasons. Adjustment for differences in depreciation rates was remitted for fresh consideration, and pre-operative expenses were directed to be excluded from operating costs for ALP computation. Case-Laws Income Tax Wed, 05 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243714