https://www.taxtmi.com/caselaws?id=422090 The Tribunal allowed the appeals of the assessee, directing the deletion of adjustments made by the AO and TPO. It emphasized functional comparability and adherence to judicial precedents in transfer pricing matters. The Tribunal ruled in favor of the assessee on various issues including transfer pricing adjustments, capitalization of software expenses, exclusion of communication charges and expenditure in foreign currency from export turnover, and the initiation of penalty under Section 271(1)(c). The order ensured a consistent approach in computing deductions under Section 10A by excluding certain expenses from both export turnover and total turnover. en-us Mon, 16 Aug 2021 00:00:00 +0530 Sat, 07 May 2022 12:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=422090 The Tribunal allowed the appeals of the assessee, directing the deletion of adjustments made by the AO and TPO. It emphasized functional comparability and adherence to judicial precedents in transfer pricing matters. The Tribunal ruled in favor of the assessee on various issues including transfer pricing adjustments, capitalization of software expenses, exclusion of communication charges and expenditure in foreign currency from export turnover, and the initiation of penalty under Section 271(1)(c). The order ensured a consistent approach in computing deductions under Section 10A by excluding certain expenses from both export turnover and total turnover. Case-Laws Income Tax Mon, 16 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=422090