https://www.taxtmi.com/caselaws?id=191764 ITAT Bangalore upheld the selection of comparables for transfer pricing by excluding companies functionally dissimilar to the assessee, which provides software services, rejecting merger events as a ground for exclusion if the amalgamated company operates in the same business. The tribunal affirmed the denial of deduction under section 10A for recruitment fees, relying on SC precedent that only receipts directly linked to export activities qualify for such deduction. Since recruitment fees, interest, and miscellaneous income lacked nexus with software export, they were excluded from business profits for section 10A benefits. The decision was against the assessee. en-us Wed, 06 Apr 2016 00:00:00 +0530 Thu, 24 Jul 2025 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191764 ITAT Bangalore upheld the selection of comparables for transfer pricing by excluding companies functionally dissimilar to the assessee, which provides software services, rejecting merger events as a ground for exclusion if the amalgamated company operates in the same business. The tribunal affirmed the denial of deduction under section 10A for recruitment fees, relying on SC precedent that only receipts directly linked to export activities qualify for such deduction. Since recruitment fees, interest, and miscellaneous income lacked nexus with software export, they were excluded from business profits for section 10A benefits. The decision was against the assessee. Case-Laws Income Tax Wed, 06 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191764