https://www.taxtmi.com/caselaws?id=405600 The Tribunal partly allowed both the revenue and assessee's appeals, remanding several issues back to the AO/TPO for reconsideration. The decision stressed the significance of functional comparability and consistent application of filters in Transfer Pricing analysis, aligning with precedents set by higher judicial authorities. Notable outcomes included the allowance of software expenses under section 40(a)(i) and directives on MAT credit, TDS credits, working capital adjustments, and deductions under section 10A without setting off business losses. The decision underscored the need for meticulous analysis and adherence to legal standards in resolving complex tax matters. en-us Thu, 11 Mar 2021 00:00:00 +0530 Tue, 08 Jun 2021 14:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405600 The Tribunal partly allowed both the revenue and assessee's appeals, remanding several issues back to the AO/TPO for reconsideration. The decision stressed the significance of functional comparability and consistent application of filters in Transfer Pricing analysis, aligning with precedents set by higher judicial authorities. Notable outcomes included the allowance of software expenses under section 40(a)(i) and directives on MAT credit, TDS credits, working capital adjustments, and deductions under section 10A without setting off business losses. The decision underscored the need for meticulous analysis and adherence to legal standards in resolving complex tax matters. Case-Laws Income Tax Thu, 11 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405600