https://www.taxtmi.com/caselaws?id=291821 The ITAT partially allowed the assessee's appeal, directing the TPO to exclude certain companies from comparables due to functional dissimilarities and include others after verification. It ordered software and training expenses to be treated as revenue expenditure. The issue of depreciation on goodwill was remanded for reassessment. Grounds related to interest under sections 234B and 234D, and penalty proceedings under section 271(1)(c) were dismissed as not pressed. The decision highlighted the importance of functional comparability and risk adjustments in transfer pricing assessments. en-us Tue, 28 May 2019 00:00:00 +0530 Wed, 13 Nov 2024 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=291821 The ITAT partially allowed the assessee's appeal, directing the TPO to exclude certain companies from comparables due to functional dissimilarities and include others after verification. It ordered software and training expenses to be treated as revenue expenditure. The issue of depreciation on goodwill was remanded for reassessment. Grounds related to interest under sections 234B and 234D, and penalty proceedings under section 271(1)(c) were dismissed as not pressed. The decision highlighted the importance of functional comparability and risk adjustments in transfer pricing assessments. Case-Laws Income Tax Tue, 28 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=291821