https://www.taxtmi.com/caselaws?id=364440 The Tribunal upheld the Taxation Authority's decision to reject the Cost Plus Method and the Comparable Uncontrolled Price Method, opting for the Transactional Net Margin Method as the most suitable for determining arm's length price. The Tribunal supported the inclusion of Persistent Systems Ltd. and directed the inclusion of Akshay Software Technologies Ltd. and Evoke Technologies Ltd. while excluding various companies due to functional disparities and lack of segmental data. The Tribunal endorsed the Taxation Authority's application of filters and use of current year data, emphasizing the importance of consistency and accurate data for Transfer Pricing studies. The appeal was partially allowed, with specific directions on comparable company inclusion and exclusion. en-us Tue, 13 Mar 2018 00:00:00 +0530 Mon, 27 Aug 2018 09:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=364440 The Tribunal upheld the Taxation Authority's decision to reject the Cost Plus Method and the Comparable Uncontrolled Price Method, opting for the Transactional Net Margin Method as the most suitable for determining arm's length price. The Tribunal supported the inclusion of Persistent Systems Ltd. and directed the inclusion of Akshay Software Technologies Ltd. and Evoke Technologies Ltd. while excluding various companies due to functional disparities and lack of segmental data. The Tribunal endorsed the Taxation Authority's application of filters and use of current year data, emphasizing the importance of consistency and accurate data for Transfer Pricing studies. The appeal was partially allowed, with specific directions on comparable company inclusion and exclusion. Case-Laws Income Tax Tue, 13 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=364440