https://www.taxtmi.com/caselaws?id=374600 In transfer pricing, comparable companies with related party transactions up to 15% of sales were treated as includible, and a zero-percent filter was not sustained. Kals Information Systems Ltd. was not finally accepted as comparable because its functional profile and segmental material required fresh verification, so the matter was remanded for reconsideration. Delayed receivables from an associated enterprise were treated as part of the underlying sale or service transaction, not a separate international transaction, and the separate adjustment on that basis was deleted. Depreciation on capitalised software expenditure could not be disallowed under section 40(a)(ia) merely for non-deduction of tax at source, so that disallowance was also deleted. en-us Fri, 21 Dec 2018 00:00:00 +0530 Tue, 05 Feb 2019 13:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=374600 In transfer pricing, comparable companies with related party transactions up to 15% of sales were treated as includible, and a zero-percent filter was not sustained. Kals Information Systems Ltd. was not finally accepted as comparable because its functional profile and segmental material required fresh verification, so the matter was remanded for reconsideration. Delayed receivables from an associated enterprise were treated as part of the underlying sale or service transaction, not a separate international transaction, and the separate adjustment on that basis was deleted. Depreciation on capitalised software expenditure could not be disallowed under section 40(a)(ia) merely for non-deduction of tax at source, so that disallowance was also deleted. Case-Laws Income Tax Fri, 21 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374600