https://www.taxtmi.com/caselaws?id=274439 In determining arm's length price for international transactions in the software R&D services and IT back-office support services segments, the ITAT held that selection of comparables must reflect functional similarity and appropriate filters; it therefore directed exclusion/inclusion of specific comparables as warranted, resulting in partial allowance of the transfer pricing grounds for statistical purposes. On exemption under s.10A, the ITAT found the allocation of directors' remuneration between the eligible STP unit and the non-eligible unit required proper verification on facts and consistent allocation principles; it remanded the issue to the AO for fresh examination, leaving the s.10A claim open to recomputation accordingly. en-us Fri, 05 Jan 2018 00:00:00 +0530 Wed, 31 Dec 2025 10:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274439 In determining arm's length price for international transactions in the software R&D services and IT back-office support services segments, the ITAT held that selection of comparables must reflect functional similarity and appropriate filters; it therefore directed exclusion/inclusion of specific comparables as warranted, resulting in partial allowance of the transfer pricing grounds for statistical purposes. On exemption under s.10A, the ITAT found the allocation of directors' remuneration between the eligible STP unit and the non-eligible unit required proper verification on facts and consistent allocation principles; it remanded the issue to the AO for fresh examination, leaving the s.10A claim open to recomputation accordingly. Case-Laws Income Tax Fri, 05 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274439