https://www.taxtmi.com/caselaws?id=304946 The Tribunal allowed the appeal regarding a transfer pricing adjustment of Rs.13,48,02,885 for the assessment year 2014-15 under the Income-tax Act, 1961. The dispute focused on the inclusion of certain companies in the comparables list for software support services. The Tribunal excluded companies like Persistent Systems Ltd., Thirdware Solutions Ltd., and R.S. Software Ltd. due to functional dissimilarities and extraordinary financial events, emphasizing the importance of functional similarity in comparability analysis. The impugned order was set aside, directing a fresh determination of the Arm's Length Price by the AO/TPO, ensuring the assessee's right to a fair hearing. en-us Thu, 23 Sep 2021 00:00:00 +0530 Mon, 07 Nov 2022 23:15:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304946 The Tribunal allowed the appeal regarding a transfer pricing adjustment of Rs.13,48,02,885 for the assessment year 2014-15 under the Income-tax Act, 1961. The dispute focused on the inclusion of certain companies in the comparables list for software support services. The Tribunal excluded companies like Persistent Systems Ltd., Thirdware Solutions Ltd., and R.S. Software Ltd. due to functional dissimilarities and extraordinary financial events, emphasizing the importance of functional similarity in comparability analysis. The impugned order was set aside, directing a fresh determination of the Arm's Length Price by the AO/TPO, ensuring the assessee's right to a fair hearing. Case-Laws Income Tax Thu, 23 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304946