https://www.taxtmi.com/caselaws?id=431340 The case involved disputes over Arms Length Price (ALP) determination in international transactions. The Transfer Pricing Officer (TPO) suggested an upward adjustment, upheld by the Dispute Resolution Panel (DRP) and Assessing Officer. The inclusion/exclusion of comparables was contentious, with challenges regarding specific entities like Eclerx Services Ltd. and Infosys BPO Ltd. Additionally, disputes arose over the treatment of management fee, trade mark license fee, and software license fee. The Tribunal's decision partially allowed the assessee's appeal, addressing complex transfer pricing issues based on detailed analysis and past precedents. en-us Thu, 22 Sep 2022 00:00:00 +0530 Sat, 10 Dec 2022 10:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431340 The case involved disputes over Arms Length Price (ALP) determination in international transactions. The Transfer Pricing Officer (TPO) suggested an upward adjustment, upheld by the Dispute Resolution Panel (DRP) and Assessing Officer. The inclusion/exclusion of comparables was contentious, with challenges regarding specific entities like Eclerx Services Ltd. and Infosys BPO Ltd. Additionally, disputes arose over the treatment of management fee, trade mark license fee, and software license fee. The Tribunal's decision partially allowed the assessee's appeal, addressing complex transfer pricing issues based on detailed analysis and past precedents. Case-Laws Income Tax Thu, 22 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431340