https://www.taxtmi.com/caselaws?id=422095 The Revenue's appeal was dismissed due to low tax effect. The Arm's Length Price (ALP) for software development services was contested, with adjustments reduced. Working capital adjustment was disallowed as the assessee had no working capital risk. Certain comparable companies were excluded and included, with directions for fresh consideration. Extraordinary expenses in operating margin were remanded for further review. An ALP adjustment offered to tax twice was directed for fresh consideration. Provision for rental expenses deduction was disallowed. The Revenue's appeal was dismissed, and the assessee's appeal was partly allowed for statistical purposes, with detailed directions for reconsideration provided. en-us Mon, 07 Feb 2022 00:00:00 +0530 Mon, 09 May 2022 08:39:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=422095 The Revenue's appeal was dismissed due to low tax effect. The Arm's Length Price (ALP) for software development services was contested, with adjustments reduced. Working capital adjustment was disallowed as the assessee had no working capital risk. Certain comparable companies were excluded and included, with directions for fresh consideration. Extraordinary expenses in operating margin were remanded for further review. An ALP adjustment offered to tax twice was directed for fresh consideration. Provision for rental expenses deduction was disallowed. The Revenue's appeal was dismissed, and the assessee's appeal was partly allowed for statistical purposes, with detailed directions for reconsideration provided. Case-Laws Income Tax Mon, 07 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=422095