https://www.taxtmi.com/caselaws?id=303914 In transfer pricing for a captive software development service provider, full-fledged software businesses with materially different functions and very high turnover were treated as not comparables, so their exclusion was upheld. Depreciation was also directed to be removed from the operating cost base of both the tested party and comparables to ensure like-to-like margin computation, and that adjustment was sustained. On software purchase payments, disallowance for non-deduction of tax at source was maintained under the settled approach applying the tax deduction obligation. By contrast, the section 14A disallowance was deleted because no exempt income was earned during the year. en-us Wed, 04 Sep 2019 00:00:00 +0530 Wed, 24 Aug 2022 22:29:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=303914 In transfer pricing for a captive software development service provider, full-fledged software businesses with materially different functions and very high turnover were treated as not comparables, so their exclusion was upheld. Depreciation was also directed to be removed from the operating cost base of both the tested party and comparables to ensure like-to-like margin computation, and that adjustment was sustained. On software purchase payments, disallowance for non-deduction of tax at source was maintained under the settled approach applying the tax deduction obligation. By contrast, the section 14A disallowance was deleted because no exempt income was earned during the year. Case-Laws Income Tax Wed, 04 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=303914