https://www.taxtmi.com/caselaws?id=388084 Transfer pricing disputes involving AMP expenditure, software development services, marketing support services, intra-group services and reimbursements turned on functional comparability, reliable segmental data, filter selection, and the need for proper verification before any nil valuation or fresh computation. The commentary also notes that working capital adjustment was allowed for reconsideration, risk adjustment was remanded, and several comparables were excluded for functional dissimilarity, public sector character, extraordinary events, or lack of segmental results. It further states that liquidated damages accrued on contractual delay and were treated as deductible business expenditure, while software expenses and the section 10A/10B deduction claims required factual re-examination. en-us Thu, 31 Oct 2019 00:00:00 +0530 Thu, 07 Nov 2019 08:24:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=388084 Transfer pricing disputes involving AMP expenditure, software development services, marketing support services, intra-group services and reimbursements turned on functional comparability, reliable segmental data, filter selection, and the need for proper verification before any nil valuation or fresh computation. The commentary also notes that working capital adjustment was allowed for reconsideration, risk adjustment was remanded, and several comparables were excluded for functional dissimilarity, public sector character, extraordinary events, or lack of segmental results. It further states that liquidated damages accrued on contractual delay and were treated as deductible business expenditure, while software expenses and the section 10A/10B deduction claims required factual re-examination. Case-Laws Income Tax Thu, 31 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=388084