https://www.taxtmi.com/caselaws?id=412095 In transfer pricing, a MAP-determined arm's length margin applied in the assessee's own case for a similar software development segment was extended to non-USA associated enterprise transactions because no separate functional distinction was shown. In the ITES segment, comparables such as Acropetal Technologies Ltd., Jeevan Scientific Technology Ltd., and Infosys BPO Ltd. were treated as unreliable due to functional dissimilarity, KPO features, scale, brand value, diversified activities, abnormal margin movement, and filter failures, so their exclusion was sustained. For section 10A computation, expenditure excluded from export turnover was also required to be excluded from total turnover to maintain parity in the deduction formula. en-us Wed, 01 Sep 2021 00:00:00 +0530 Thu, 09 Sep 2021 11:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412095 In transfer pricing, a MAP-determined arm's length margin applied in the assessee's own case for a similar software development segment was extended to non-USA associated enterprise transactions because no separate functional distinction was shown. In the ITES segment, comparables such as Acropetal Technologies Ltd., Jeevan Scientific Technology Ltd., and Infosys BPO Ltd. were treated as unreliable due to functional dissimilarity, KPO features, scale, brand value, diversified activities, abnormal margin movement, and filter failures, so their exclusion was sustained. For section 10A computation, expenditure excluded from export turnover was also required to be excluded from total turnover to maintain parity in the deduction formula. Case-Laws Income Tax Wed, 01 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412095