https://www.taxtmi.com/caselaws?id=306307 The Tribunal partly allowed the appeal, upholding the inclusion of certain comparables for Transfer Pricing adjustments while excluding others based on size and brand value. It supported reducing communication expenses and insurance charges from export turnover for deduction u/s 10AA. The Tribunal disallowed the disallowance under Section 40(a)(i) for software import due to the transaction nature. The issue of depreciation on software was deemed infructuous, and software purchase expenditure was treated as revenue expenditure for deduction despite no TDS deduction. en-us Wed, 10 Mar 2021 00:00:00 +0530 Sat, 21 Jan 2023 08:50:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306307 The Tribunal partly allowed the appeal, upholding the inclusion of certain comparables for Transfer Pricing adjustments while excluding others based on size and brand value. It supported reducing communication expenses and insurance charges from export turnover for deduction u/s 10AA. The Tribunal disallowed the disallowance under Section 40(a)(i) for software import due to the transaction nature. The issue of depreciation on software was deemed infructuous, and software purchase expenditure was treated as revenue expenditure for deduction despite no TDS deduction. Case-Laws Income Tax Wed, 10 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306307