https://www.taxtmi.com/caselaws?id=386486 The appeal challenged the adjustment of arms length pricing on the entire turnover instead of just international transactions. The Tribunal directed a re-computation of the transfer pricing adjustment, emphasizing that arms length pricing should only apply to international transactions. The application of safe harbor limits and the exclusion of certain comparables were also addressed, with directions given for reconsideration. The dispute over the disallowance of expenditure on computer software was remitted for further adjudication, while the disallowance of depreciation on a purchased laptop was upheld due to lack of evidence. The appeal was partly allowed for statistical purposes, with specific grounds allowed or dismissed based on the Tribunal's findings. en-us Wed, 03 Jul 2019 00:00:00 +0530 Sat, 28 Sep 2019 09:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386486 The appeal challenged the adjustment of arms length pricing on the entire turnover instead of just international transactions. The Tribunal directed a re-computation of the transfer pricing adjustment, emphasizing that arms length pricing should only apply to international transactions. The application of safe harbor limits and the exclusion of certain comparables were also addressed, with directions given for reconsideration. The dispute over the disallowance of expenditure on computer software was remitted for further adjudication, while the disallowance of depreciation on a purchased laptop was upheld due to lack of evidence. The appeal was partly allowed for statistical purposes, with specific grounds allowed or dismissed based on the Tribunal's findings. Case-Laws Income Tax Wed, 03 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386486