https://www.taxtmi.com/caselaws?id=176659 The Tribunal partly allowed the appeal, remanding specific issues to the Transfer Pricing Officer for reconsideration. The Tribunal upheld the TPO's application of filters and inclusion of FCS Software Solutions Ltd. as a comparable, while dismissing the assessee's claims on multiple year data and risk adjustments. The appeal resulted in adjustments to the ALP, with certain comparables being revised and the addition of Fringe Benefit Tax upheld. The Tribunal did not address the charging of interest under Sections 234A and 234B, and noted procedural issues regarding the initiation of penalty under Section 271(1)(c). en-us Fri, 31 May 2013 00:00:00 +0530 Mon, 24 Apr 2017 11:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176659 The Tribunal partly allowed the appeal, remanding specific issues to the Transfer Pricing Officer for reconsideration. The Tribunal upheld the TPO's application of filters and inclusion of FCS Software Solutions Ltd. as a comparable, while dismissing the assessee's claims on multiple year data and risk adjustments. The appeal resulted in adjustments to the ALP, with certain comparables being revised and the addition of Fringe Benefit Tax upheld. The Tribunal did not address the charging of interest under Sections 234A and 234B, and noted procedural issues regarding the initiation of penalty under Section 271(1)(c). Case-Laws Income Tax Fri, 31 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176659