https://www.taxtmi.com/caselaws?id=384741 The appeal in the case involved transfer pricing additions in international transactions for software development and sales support services. The court allowed the appeal partially, directing a fresh determination of Arm's Length Prices (ALPs) for these transactions. Specific companies were excluded or included as comparables based on functional dissimilarities and business profiles. The court also addressed issues related to risk adjustment, revenue inclusion, and deduction computation under section 10A. The matter was remitted back to the Assessing Officer/Transfer Pricing Officer for further proceedings. en-us Mon, 19 Aug 2019 00:00:00 +0530 Thu, 22 Aug 2019 07:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=384741 The appeal in the case involved transfer pricing additions in international transactions for software development and sales support services. The court allowed the appeal partially, directing a fresh determination of Arm's Length Prices (ALPs) for these transactions. Specific companies were excluded or included as comparables based on functional dissimilarities and business profiles. The court also addressed issues related to risk adjustment, revenue inclusion, and deduction computation under section 10A. The matter was remitted back to the Assessing Officer/Transfer Pricing Officer for further proceedings. Case-Laws Income Tax Mon, 19 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=384741