https://www.taxtmi.com/caselaws?id=249679 ITAT Delhi held that the assessee's method of determining ALP for IT-enabled services using certain comparables was flawed, excluding entities with disproportionate scale or functional differences. Captive units with low turnover were not comparable to the assessee's large-scale operations. R. Systems International Ltd. was to be included after adjusting financial year data. Working capital adjustment claims were remanded for fresh consideration. Deduction under Section 10AA was reduced and remitted for reassessment regarding interest income classification. Communication expenses incurred in foreign currency were excluded from export turnover for Section 10AA deduction computation. The tribunal partly allowed the appeal, directing reassessment and exclusion of inappropriate comparables while affirming the need for a fair working capital adjustment. en-us Fri, 06 Jun 2014 00:00:00 +0530 Mon, 28 Jul 2025 17:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249679 ITAT Delhi held that the assessee's method of determining ALP for IT-enabled services using certain comparables was flawed, excluding entities with disproportionate scale or functional differences. Captive units with low turnover were not comparable to the assessee's large-scale operations. R. Systems International Ltd. was to be included after adjusting financial year data. Working capital adjustment claims were remanded for fresh consideration. Deduction under Section 10AA was reduced and remitted for reassessment regarding interest income classification. Communication expenses incurred in foreign currency were excluded from export turnover for Section 10AA deduction computation. The tribunal partly allowed the appeal, directing reassessment and exclusion of inappropriate comparables while affirming the need for a fair working capital adjustment. Case-Laws Income Tax Fri, 06 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249679