https://www.taxtmi.com/caselaws?id=256319 Transfer pricing adjustments relating to cost allocations and cost recharges require proper verification of supporting evidence before they can be sustained, and additional evidence may justify fresh examination by the TPO/AO. Functional comparability for the IEC segment must be tested against the actual nature of each company's activities, so only entities performing comparable software development functions can be retained and broader or different software-related companies excluded. The matter was therefore remanded for reconsideration with directions for fresh determination on both issues. en-us Mon, 22 Dec 2014 00:00:00 +0530 Mon, 09 Feb 2015 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256319 Transfer pricing adjustments relating to cost allocations and cost recharges require proper verification of supporting evidence before they can be sustained, and additional evidence may justify fresh examination by the TPO/AO. Functional comparability for the IEC segment must be tested against the actual nature of each company's activities, so only entities performing comparable software development functions can be retained and broader or different software-related companies excluded. The matter was therefore remanded for reconsideration with directions for fresh determination on both issues. Case-Laws Income Tax Mon, 22 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256319