https://www.taxtmi.com/caselaws?id=403858 The Tribunal upheld the approach of the Transfer Pricing Officer (TPO) in adjusting the arm's length price of international transactions in the IT enabled segment but directed verification of functional similarity and business models of comparables. It did not delve into the jurisdictional error of referring the matter to the TPO. The Tribunal directed verification of comparables, including Cosmic Global Ltd., and computation of correct operating margins for R Systems International Ltd. It upheld the exclusion of certain comparables due to functional dissimilarity, extraordinary events, or public sector status, while setting aside the exclusion of HCL Comnet Systems and Services Ltd. en-us Mon, 25 Jan 2021 00:00:00 +0530 Mon, 08 Feb 2021 16:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=403858 The Tribunal upheld the approach of the Transfer Pricing Officer (TPO) in adjusting the arm's length price of international transactions in the IT enabled segment but directed verification of functional similarity and business models of comparables. It did not delve into the jurisdictional error of referring the matter to the TPO. The Tribunal directed verification of comparables, including Cosmic Global Ltd., and computation of correct operating margins for R Systems International Ltd. It upheld the exclusion of certain comparables due to functional dissimilarity, extraordinary events, or public sector status, while setting aside the exclusion of HCL Comnet Systems and Services Ltd. Case-Laws Income Tax Mon, 25 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=403858