https://www.taxtmi.com/caselaws?id=424934 The Tribunal partly allowed the appeal by the assessee in a transfer pricing case involving determination of Arm's Length Price (ALP) in the SWD services and Trading segments. The Tribunal upheld exclusions of certain comparables due to functional dissimilarity and lack of segmental data, remanded others for fresh consideration, and directed a working capital adjustment. In the Trading segment, the Tribunal directed the adoption of Resale Price Method as the Most Appropriate Method. Additionally, the Tribunal directed the Revenue to grant depreciation at 60% for computer software and deleted the disallowance of the warranty provision. en-us Thu, 30 Jun 2022 00:00:00 +0530 Mon, 11 Jul 2022 10:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=424934 The Tribunal partly allowed the appeal by the assessee in a transfer pricing case involving determination of Arm's Length Price (ALP) in the SWD services and Trading segments. The Tribunal upheld exclusions of certain comparables due to functional dissimilarity and lack of segmental data, remanded others for fresh consideration, and directed a working capital adjustment. In the Trading segment, the Tribunal directed the adoption of Resale Price Method as the Most Appropriate Method. Additionally, the Tribunal directed the Revenue to grant depreciation at 60% for computer software and deleted the disallowance of the warranty provision. Case-Laws Income Tax Thu, 30 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=424934