https://www.taxtmi.com/caselaws?id=257465 ITAT allowed the assessee's transfer-pricing contentions: OP/total-cost PLI was fixed at 9% (not 6.88%). Several alleged comparables were excluded for lack of functional similarity or segmental data, while one comparable was retained; transfer-pricing addition was restricted to Rs. 17,32,27,953. For international support-services the Tribunal found the prices were at arm's length and disallowed adjustment. On Sec.10A deductions the Tribunal upheld the assessee's employee-count basis for allocating recruitment, accepted travel allocation subject to identification of hotel charges for 10A projects, upheld software-license allocation, but sustained AO's turnover-based allocation for communication costs. Classification of computer software (revenue v. capital) was remitted for reconsideration. en-us Thu, 28 Feb 2013 00:00:00 +0530 Thu, 06 Nov 2025 14:20:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257465 ITAT allowed the assessee's transfer-pricing contentions: OP/total-cost PLI was fixed at 9% (not 6.88%). Several alleged comparables were excluded for lack of functional similarity or segmental data, while one comparable was retained; transfer-pricing addition was restricted to Rs. 17,32,27,953. For international support-services the Tribunal found the prices were at arm's length and disallowed adjustment. On Sec.10A deductions the Tribunal upheld the assessee's employee-count basis for allocating recruitment, accepted travel allocation subject to identification of hotel charges for 10A projects, upheld software-license allocation, but sustained AO's turnover-based allocation for communication costs. Classification of computer software (revenue v. capital) was remitted for reconsideration. Case-Laws Income Tax Thu, 28 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257465