https://www.taxtmi.com/caselaws?id=260677 The Tribunal remitted the issue of disallowance of consultancy charges back to the Transfer Pricing Officer for fresh examination, considering past accepted payments. It directed the exclusion of high-scale companies as comparables due to brand and scale differences. Disallowances under Section 40(a)(i) were deleted for software payments. Communication expenses were excluded from export turnover for Section 10A deduction. The Tribunal allowed 50% of guest house maintenance and picnic expenses, ensuring a fair resolution. Appeals were partly allowed, providing clear directions for each issue based on legal principles and past decisions. en-us Thu, 30 Apr 2015 00:00:00 +0530 Sat, 20 Jun 2015 05:50:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260677 The Tribunal remitted the issue of disallowance of consultancy charges back to the Transfer Pricing Officer for fresh examination, considering past accepted payments. It directed the exclusion of high-scale companies as comparables due to brand and scale differences. Disallowances under Section 40(a)(i) were deleted for software payments. Communication expenses were excluded from export turnover for Section 10A deduction. The Tribunal allowed 50% of guest house maintenance and picnic expenses, ensuring a fair resolution. Appeals were partly allowed, providing clear directions for each issue based on legal principles and past decisions. Case-Laws Income Tax Thu, 30 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260677