https://www.taxtmi.com/caselaws?id=406465 The Tribunal upheld the exclusion of certain comparables in the Transfer Pricing (TP) analysis due to differences in size and functional dissimilarities. It directed adjustments to the Arm's Length Price (ALP) of international transactions and allowed set-off of business losses. The Tribunal held that the voluntary TP adjustment qualifies for deduction under Section 10A and directed the exclusion of certain expenses from export turnover for Section 10A deduction. The appeal by the assessee was allowed, and the revenue's appeal was partly allowed. en-us Thu, 01 Apr 2021 00:00:00 +0530 Thu, 15 Apr 2021 08:05:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406465 The Tribunal upheld the exclusion of certain comparables in the Transfer Pricing (TP) analysis due to differences in size and functional dissimilarities. It directed adjustments to the Arm's Length Price (ALP) of international transactions and allowed set-off of business losses. The Tribunal held that the voluntary TP adjustment qualifies for deduction under Section 10A and directed the exclusion of certain expenses from export turnover for Section 10A deduction. The appeal by the assessee was allowed, and the revenue's appeal was partly allowed. Case-Laws Income Tax Thu, 01 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406465