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    <title>2014 (9) TMI 126 - ITAT HYDERABAD</title>
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    <description>ITAT Hyderabad partly allowed the assessee&#039;s appeal in a transfer pricing matter. The tribunal excluded Infosys BPO Ltd., Genesys International Ltd., Eclerx Services Ltd., Cosmic Global Ltd., Acropetal Technologies Ltd., and Accentia Technologies Ltd. as comparables due to functional dissimilarity, different business strategies, or segmental differences. Crossdomain Solutions Pvt. Ltd. was held functionally comparable, and the AO/TPO was directed to verify revenue variations. Regarding deduction under section 10A, communication expenses were to be excluded from both export and total turnover for computation. On brought forward business losses, the AO was directed to allow the assessee to demonstrate entitlement to set off losses notionally against current income before any disallowance. The decision was thus partly in favour of the assessee.</description>
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      <title>2014 (9) TMI 126 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=251100</link>
      <description>ITAT Hyderabad partly allowed the assessee&#039;s appeal in a transfer pricing matter. The tribunal excluded Infosys BPO Ltd., Genesys International Ltd., Eclerx Services Ltd., Cosmic Global Ltd., Acropetal Technologies Ltd., and Accentia Technologies Ltd. as comparables due to functional dissimilarity, different business strategies, or segmental differences. Crossdomain Solutions Pvt. Ltd. was held functionally comparable, and the AO/TPO was directed to verify revenue variations. Regarding deduction under section 10A, communication expenses were to be excluded from both export and total turnover for computation. On brought forward business losses, the AO was directed to allow the assessee to demonstrate entitlement to set off losses notionally against current income before any disallowance. The decision was thus partly in favour of the assessee.</description>
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