https://www.taxtmi.com/caselaws?id=299836 Transfer pricing analysis for a captive software development service provider excluded functionally different comparables on FAR grounds and sent one unexamined comparable back for fresh FAR consideration. The adjustment was confined to international transactions with associated enterprises and could not be extended to domestic transactions. Depreciation at 60% on computer peripherals was recognised in line with the DRP direction. Education cess and secondary and higher education cess were treated as allowable business deductions under binding precedent. en-us Fri, 23 Jul 2021 00:00:00 +0530 Fri, 31 Dec 2021 08:51:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=299836 Transfer pricing analysis for a captive software development service provider excluded functionally different comparables on FAR grounds and sent one unexamined comparable back for fresh FAR consideration. The adjustment was confined to international transactions with associated enterprises and could not be extended to domestic transactions. Depreciation at 60% on computer peripherals was recognised in line with the DRP direction. Education cess and secondary and higher education cess were treated as allowable business deductions under binding precedent. Case-Laws Income Tax Fri, 23 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=299836