https://www.taxtmi.com/caselaws?id=257905 The Tribunal held that transfer pricing provisions apply regardless of income exemption under section 10A of the Income-tax Act. Various comparables were excluded/included based on specific criteria. Return on Asset Employed (ROA) or Return on Capital Employed (ROCA) were deemed unsuitable for margin computation in service sectors. Working capital adjustment was mandated for comparability, following OECD guidelines. The claim for adjustment on linked costs was rejected. The benefit of +/-5% deviation in margin computation was denied. Both appeals were partly allowed, with directions for adjustments by the Assessing Officer/Transfer Pricing Officer. en-us Fri, 26 Apr 2013 00:00:00 +0530 Sun, 03 May 2015 11:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257905 The Tribunal held that transfer pricing provisions apply regardless of income exemption under section 10A of the Income-tax Act. Various comparables were excluded/included based on specific criteria. Return on Asset Employed (ROA) or Return on Capital Employed (ROCA) were deemed unsuitable for margin computation in service sectors. Working capital adjustment was mandated for comparability, following OECD guidelines. The claim for adjustment on linked costs was rejected. The benefit of +/-5% deviation in margin computation was denied. Both appeals were partly allowed, with directions for adjustments by the Assessing Officer/Transfer Pricing Officer. Case-Laws Income Tax Fri, 26 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257905