https://www.taxtmi.com/caselaws?id=303805 The Tribunal partly allowed the appeal, directing the AO/TPO to re-compute the Arm's Length Price (ALP) for the international transaction of rendering Software Development Services (SWD) and the delayed realization of receivables. The Tribunal emphasized the exclusion of companies with high turnovers and the application of a 15% Related Party Transactions (RPT) threshold. The Assessee was granted an opportunity to be heard in the fresh examination of these issues. en-us Mon, 25 Oct 2021 00:00:00 +0530 Tue, 16 Aug 2022 09:04:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=303805 The Tribunal partly allowed the appeal, directing the AO/TPO to re-compute the Arm's Length Price (ALP) for the international transaction of rendering Software Development Services (SWD) and the delayed realization of receivables. The Tribunal emphasized the exclusion of companies with high turnovers and the application of a 15% Related Party Transactions (RPT) threshold. The Assessee was granted an opportunity to be heard in the fresh examination of these issues. Case-Laws Income Tax Mon, 25 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=303805