https://www.taxtmi.com/caselaws?id=196159 The appeal by the assessee was partly allowed, with specific directions given for the exclusion of certain comparables, allowance of working capital adjustment without an upper limit, and treatment of software expenses as revenue expenditure. The Tribunal emphasized the importance of using contemporaneous data in transfer pricing assessments and directed the Tax Authorities to conduct a thorough analysis when making adjustments to ensure compliance with arm's length pricing principles. en-us Fri, 27 Nov 2015 00:00:00 +0530 Tue, 21 Nov 2017 08:40:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=196159 The appeal by the assessee was partly allowed, with specific directions given for the exclusion of certain comparables, allowance of working capital adjustment without an upper limit, and treatment of software expenses as revenue expenditure. The Tribunal emphasized the importance of using contemporaneous data in transfer pricing assessments and directed the Tax Authorities to conduct a thorough analysis when making adjustments to ensure compliance with arm's length pricing principles. Case-Laws Income Tax Fri, 27 Nov 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=196159