https://www.taxtmi.com/caselaws?id=281383 Transfer pricing comparability analysis must ordinarily use contemporaneous annual data, and multiple-year data was rejected on the facts noted. Companies with diversified or specialised operations, or without reliable segmental information, were excluded from the comparables set, including entities engaged in software products, mixed software and IT services, and complex specialised activities. Provision for bad and doubtful debts was treated as operating expenditure for margin computation. For section 10A, deduction was allowed on a voluntary transfer pricing adjustment returned by the assessee, and internet and communication charges were required to be excluded from both export turnover and total turnover for parity in computation. en-us Fri, 23 Sep 2016 00:00:00 +0530 Mon, 17 Jun 2019 21:52:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=281383 Transfer pricing comparability analysis must ordinarily use contemporaneous annual data, and multiple-year data was rejected on the facts noted. Companies with diversified or specialised operations, or without reliable segmental information, were excluded from the comparables set, including entities engaged in software products, mixed software and IT services, and complex specialised activities. Provision for bad and doubtful debts was treated as operating expenditure for margin computation. For section 10A, deduction was allowed on a voluntary transfer pricing adjustment returned by the assessee, and internet and communication charges were required to be excluded from both export turnover and total turnover for parity in computation. Case-Laws Income Tax Fri, 23 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=281383