https://www.taxtmi.com/caselaws?id=259493 The Tribunal partially allowed the appeal of the assessee in a transfer pricing case involving software development services. It concluded that after excluding non-comparable companies and considering appropriate segmental data, the profit margin of the remaining comparables aligned closely with the assessee's margin. Therefore, no adjustment to the Arm's Length Price was deemed necessary. The Tribunal emphasized the importance of selecting functionally similar comparables and following its directions for determining the ALP under Section 92CA of the Income Tax Act. en-us Fri, 10 Apr 2015 00:00:00 +0530 Tue, 12 May 2015 06:55:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259493 The Tribunal partially allowed the appeal of the assessee in a transfer pricing case involving software development services. It concluded that after excluding non-comparable companies and considering appropriate segmental data, the profit margin of the remaining comparables aligned closely with the assessee's margin. Therefore, no adjustment to the Arm's Length Price was deemed necessary. The Tribunal emphasized the importance of selecting functionally similar comparables and following its directions for determining the ALP under Section 92CA of the Income Tax Act. Case-Laws Income Tax Fri, 10 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259493