https://www.taxtmi.com/caselaws?id=404179 ITAT held that companies with turnover exceeding Rs.200 crore cannot be used as comparables for an assessee with turnover below Rs.200 crore and excluded several listed comparables; entities providing materially different functions from the assessee were also excluded. On R&D/website development expenditures treated as disallowance under s.37, the tribunal found conflicting descriptions of the expenses and that their nature (capital vs. revenue) and possible treatment under s.35 could not be determined on record; it set aside the AO's order and remanded the issue for fresh examination after giving the assessee an opportunity to be heard. en-us Mon, 15 Feb 2021 00:00:00 +0530 Fri, 29 Aug 2025 14:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404179 ITAT held that companies with turnover exceeding Rs.200 crore cannot be used as comparables for an assessee with turnover below Rs.200 crore and excluded several listed comparables; entities providing materially different functions from the assessee were also excluded. On R&D/website development expenditures treated as disallowance under s.37, the tribunal found conflicting descriptions of the expenses and that their nature (capital vs. revenue) and possible treatment under s.35 could not be determined on record; it set aside the AO's order and remanded the issue for fresh examination after giving the assessee an opportunity to be heard. Case-Laws Income Tax Mon, 15 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404179