https://www.taxtmi.com/caselaws?id=287923 The Tribunal remanded the case back to the Dispute Resolution Panel for a fresh decision, emphasizing the need for consistency in applying new filters to all comparables in the transfer pricing adjustments in the software development segment. The Tribunal upheld the exclusion of certain companies as comparables based on significant onsite software development expenses. It directed a comprehensive review of all comparables based on the new filter and other relevant criteria. The Tribunal also supported the application of the onsite filter in transfer pricing studies and declined to interfere with the treatment of expenditure in foreign currency for deductions under section 10A, following a precedent set by the Karnataka High Court. The Tribunal allowed the assessee's appeal for statistical purposes and partly allowed the revenue's appeal. en-us Fri, 17 Nov 2017 00:00:00 +0530 Wed, 13 May 2020 15:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=287923 The Tribunal remanded the case back to the Dispute Resolution Panel for a fresh decision, emphasizing the need for consistency in applying new filters to all comparables in the transfer pricing adjustments in the software development segment. The Tribunal upheld the exclusion of certain companies as comparables based on significant onsite software development expenses. It directed a comprehensive review of all comparables based on the new filter and other relevant criteria. The Tribunal also supported the application of the onsite filter in transfer pricing studies and declined to interfere with the treatment of expenditure in foreign currency for deductions under section 10A, following a precedent set by the Karnataka High Court. The Tribunal allowed the assessee's appeal for statistical purposes and partly allowed the revenue's appeal. Case-Laws Income Tax Fri, 17 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=287923