https://www.taxtmi.com/caselaws?id=281995 The Tribunal upheld the exclusion of M/s. EClerx Services Ltd. and M/s. Acropetal Technologies Ltd. as comparables, citing functional dissimilarities. Additionally, the Transfer Pricing adjustment was limited to the margin retained by the Associated Enterprises, in line with previous court decisions. The Tribunal dismissed the Revenue's appeal, confirming the decisions of the Dispute Resolution Panel on both issues, emphasizing the importance of functional comparability and preventing artificial profit shifting in Transfer Pricing adjustments. en-us Mon, 15 Apr 2019 00:00:00 +0530 Wed, 17 Jul 2019 07:48:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=281995 The Tribunal upheld the exclusion of M/s. EClerx Services Ltd. and M/s. Acropetal Technologies Ltd. as comparables, citing functional dissimilarities. Additionally, the Transfer Pricing adjustment was limited to the margin retained by the Associated Enterprises, in line with previous court decisions. The Tribunal dismissed the Revenue's appeal, confirming the decisions of the Dispute Resolution Panel on both issues, emphasizing the importance of functional comparability and preventing artificial profit shifting in Transfer Pricing adjustments. Case-Laws Income Tax Mon, 15 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=281995