https://www.taxtmi.com/caselaws?id=386205 ITAT Hyderabad held that the assessee, a captive software development service provider to its AE, earned a higher margin than the average of comparables; therefore, its international transaction was at arm's length and no TP adjustment was warranted. Hartron Communications Ltd was directed to be excluded applying the peculiar-circumstances filter for an exceptional performance year. Microgenetics Systems Ltd was held functionally dissimilar due to outsourcing of medical transcription, and thus unsuitable as a comparable. The functional profile of Infosys Technologies Ltd and Ace BPO Services Ltd, along with correct application of filters (including operating revenue and RPT), was remanded to the AO/TPO for fresh examination after granting the assessee due opportunity of hearing. en-us Tue, 06 Aug 2019 00:00:00 +0530 Mon, 08 Dec 2025 17:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386205 ITAT Hyderabad held that the assessee, a captive software development service provider to its AE, earned a higher margin than the average of comparables; therefore, its international transaction was at arm's length and no TP adjustment was warranted. Hartron Communications Ltd was directed to be excluded applying the peculiar-circumstances filter for an exceptional performance year. Microgenetics Systems Ltd was held functionally dissimilar due to outsourcing of medical transcription, and thus unsuitable as a comparable. The functional profile of Infosys Technologies Ltd and Ace BPO Services Ltd, along with correct application of filters (including operating revenue and RPT), was remanded to the AO/TPO for fresh examination after granting the assessee due opportunity of hearing. Case-Laws Income Tax Tue, 06 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386205