https://www.taxtmi.com/caselaws?id=385205 The Tribunal allowed the appeal in part, directing the Transfer Pricing Officer (TPO) to exclude certain comparables in the Software Development Segment, bifurcate costs in the Marketing Support Services Segment, consider Technical Support Services as part of the network division, and use appropriate comparables for the ITES Segment. The TPO was instructed to reevaluate the issues based on the Tribunal's findings and the appellant's evidence, emphasizing the importance of functional similarity and segmental data in selecting comparables for international transactions. en-us Fri, 23 Aug 2019 00:00:00 +0530 Sat, 31 Aug 2019 13:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385205 The Tribunal allowed the appeal in part, directing the Transfer Pricing Officer (TPO) to exclude certain comparables in the Software Development Segment, bifurcate costs in the Marketing Support Services Segment, consider Technical Support Services as part of the network division, and use appropriate comparables for the ITES Segment. The TPO was instructed to reevaluate the issues based on the Tribunal's findings and the appellant's evidence, emphasizing the importance of functional similarity and segmental data in selecting comparables for international transactions. Case-Laws Income Tax Fri, 23 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385205