https://www.taxtmi.com/caselaws?id=406964 The tribunal allowed the assessee's arguments regarding the exclusion of communication expenses from export turnover for deductions under Section 10A and 10B, following the Karnataka High Court precedent. It upheld the headcount method for allocating common expenses among business segments, remanding for verification. The treatment of forex fluctuation losses was remanded for detailed verification. Various comparables were selected and rejected for transfer pricing analysis, with a focus on risk adjustment. The tribunal directed re-computation of the operating margin for Cyber Media Research Limited, emphasizing consistency and detailed verification in its decision. Appeals were partly allowed with specific directions for re-computation and verification by the AO/TPO. en-us Thu, 15 Apr 2021 00:00:00 +0530 Mon, 26 Apr 2021 10:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406964 The tribunal allowed the assessee's arguments regarding the exclusion of communication expenses from export turnover for deductions under Section 10A and 10B, following the Karnataka High Court precedent. It upheld the headcount method for allocating common expenses among business segments, remanding for verification. The treatment of forex fluctuation losses was remanded for detailed verification. Various comparables were selected and rejected for transfer pricing analysis, with a focus on risk adjustment. The tribunal directed re-computation of the operating margin for Cyber Media Research Limited, emphasizing consistency and detailed verification in its decision. Appeals were partly allowed with specific directions for re-computation and verification by the AO/TPO. Case-Laws Income Tax Thu, 15 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406964