https://www.taxtmi.com/caselaws?id=252079 The Tribunal found merit in the assessee's arguments and restored the matter to the Transfer Pricing Officer (TPO) for fresh adjudication on various issues, including the selection of comparables, determination of Arm's Length Price (ALP) for software sales transactions, adoption of mark-up percentage over costs, granting of working capital adjustment, consideration of the Comparable Uncontrolled Price (CUP) approach, benefit of proviso to section 92C(2) of the Income Tax Act, 1961, and effect of taxes paid/TDS on final tax liability. The appeal by the assessee was allowed for statistical purposes. en-us Wed, 27 Aug 2014 00:00:00 +0530 Thu, 09 Oct 2014 19:14:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252079 The Tribunal found merit in the assessee's arguments and restored the matter to the Transfer Pricing Officer (TPO) for fresh adjudication on various issues, including the selection of comparables, determination of Arm's Length Price (ALP) for software sales transactions, adoption of mark-up percentage over costs, granting of working capital adjustment, consideration of the Comparable Uncontrolled Price (CUP) approach, benefit of proviso to section 92C(2) of the Income Tax Act, 1961, and effect of taxes paid/TDS on final tax liability. The appeal by the assessee was allowed for statistical purposes. Case-Laws Income Tax Wed, 27 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252079