https://www.taxtmi.com/caselaws?id=289377 The Tribunal partially allowed both the assessee's and Revenue's appeals. Key determinations included upholding the non-inclusion of prior period income in current margins, allowing the assessee's deduction under section 10A, and directing the AO to exclude foreign exchange fluctuations from operating expenses. Several companies were excluded as comparables due to functional dissimilarities and lack of segmental data. The Tribunal remitted certain issues back to the AO for further examination, particularly concerning the application of filters and allowance of working capital adjustments. Penalty proceedings under section 271(1)(c) were not specifically addressed. en-us Fri, 20 Dec 2019 00:00:00 +0530 Thu, 14 Nov 2024 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289377 The Tribunal partially allowed both the assessee's and Revenue's appeals. Key determinations included upholding the non-inclusion of prior period income in current margins, allowing the assessee's deduction under section 10A, and directing the AO to exclude foreign exchange fluctuations from operating expenses. Several companies were excluded as comparables due to functional dissimilarities and lack of segmental data. The Tribunal remitted certain issues back to the AO for further examination, particularly concerning the application of filters and allowance of working capital adjustments. Penalty proceedings under section 271(1)(c) were not specifically addressed. Case-Laws Income Tax Fri, 20 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289377