https://www.taxtmi.com/caselaws?id=284087 The Tribunal upheld the inclusion of two additional comparable companies for Arm's Length Price (ALP) determination for Software Development (SWD) and Research and Development (R&D) services. It excluded certain companies from the comparables list due to functional dissimilarity and high related party transactions. The Tribunal directed the Assessing Officer to consider the Assessee's revised computation of total income and provided guidance on export turnover, domestic sales, foreign exchange treatment, warranty expenses, deferred service income, Section 10A deduction, prior period revenue reversal, and interest charges under Sections 234B and 234C. en-us Tue, 30 Apr 2019 00:00:00 +0530 Wed, 30 Oct 2019 13:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284087 The Tribunal upheld the inclusion of two additional comparable companies for Arm's Length Price (ALP) determination for Software Development (SWD) and Research and Development (R&D) services. It excluded certain companies from the comparables list due to functional dissimilarity and high related party transactions. The Tribunal directed the Assessing Officer to consider the Assessee's revised computation of total income and provided guidance on export turnover, domestic sales, foreign exchange treatment, warranty expenses, deferred service income, Section 10A deduction, prior period revenue reversal, and interest charges under Sections 234B and 234C. Case-Laws Income Tax Tue, 30 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=284087