https://www.taxtmi.com/caselaws?id=306164 The appeal filed by the assessee was partly allowed, with specific directions for the Transfer Pricing Officer (TPO) to verify and reassess certain comparables for contract software development and staffing services. The Tribunal highlighted the significance of a detailed functional analysis and the requirement for comparables to be functionally similar and devoid of related party transactions. The Tribunal also partially granted the benefit of the +/- 5 percent range under Section 92C(2) of the Act. The initiation of penalty under Section 271(1)(c) was considered premature and not addressed at this stage. en-us Wed, 11 Jul 2018 00:00:00 +0530 Sat, 14 Jan 2023 06:49:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306164 The appeal filed by the assessee was partly allowed, with specific directions for the Transfer Pricing Officer (TPO) to verify and reassess certain comparables for contract software development and staffing services. The Tribunal highlighted the significance of a detailed functional analysis and the requirement for comparables to be functionally similar and devoid of related party transactions. The Tribunal also partially granted the benefit of the +/- 5 percent range under Section 92C(2) of the Act. The initiation of penalty under Section 271(1)(c) was considered premature and not addressed at this stage. Case-Laws Income Tax Wed, 11 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306164