https://www.taxtmi.com/caselaws?id=192097 In transfer pricing analysis, Infosys Technologies Ltd. was treated as functionally dissimilar because of diversified software and product development activities and exceptionally large turnover, while L&T InfoTech Ltd. was excluded for want of segmental data; the exclusion of both companies from the comparables set was upheld. For section 10A computation, telecommunication charges and similar expenditure were to be excluded from both export turnover and total turnover, following SAK Soft Ltd. and Tata Elxsi Ltd., and that approach was upheld. ESOP expenditure was also treated as revenue expenditure, in line with Biocon Ltd., and that treatment was upheld. en-us Fri, 30 Sep 2016 00:00:00 +0530 Sat, 13 May 2017 08:51:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192097 In transfer pricing analysis, Infosys Technologies Ltd. was treated as functionally dissimilar because of diversified software and product development activities and exceptionally large turnover, while L&T InfoTech Ltd. was excluded for want of segmental data; the exclusion of both companies from the comparables set was upheld. For section 10A computation, telecommunication charges and similar expenditure were to be excluded from both export turnover and total turnover, following SAK Soft Ltd. and Tata Elxsi Ltd., and that approach was upheld. ESOP expenditure was also treated as revenue expenditure, in line with Biocon Ltd., and that treatment was upheld. Case-Laws Income Tax Fri, 30 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192097