https://www.taxtmi.com/caselaws?id=284532 The Tribunal directed the AO to readjudicate the deduction under section 10A in light of the Tata Elxsi judgment. It allowed the club membership fee as revenue expenditure, confirming the CIT(A)'s decision. The Tribunal instructed verification of foreign exchange fluctuation inclusion in operating margin of comparables. It upheld the exclusion of certain comparables for Software Development and IT Enabled Services segments, directing a re-computation of the Arm's Length Price. Assessee's cross objections were dismissed, and the appeal was partly allowed for statistical purposes, emphasizing adherence to legal precedents and functional comparability in Transfer Pricing assessments. en-us Fri, 03 Mar 2017 00:00:00 +0530 Mon, 25 Nov 2019 09:26:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284532 The Tribunal directed the AO to readjudicate the deduction under section 10A in light of the Tata Elxsi judgment. It allowed the club membership fee as revenue expenditure, confirming the CIT(A)'s decision. The Tribunal instructed verification of foreign exchange fluctuation inclusion in operating margin of comparables. It upheld the exclusion of certain comparables for Software Development and IT Enabled Services segments, directing a re-computation of the Arm's Length Price. Assessee's cross objections were dismissed, and the appeal was partly allowed for statistical purposes, emphasizing adherence to legal precedents and functional comparability in Transfer Pricing assessments. Case-Laws Income Tax Fri, 03 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=284532