https://www.taxtmi.com/caselaws?id=433342 The Tribunal directed the Assessing Officer to exclude M/s Acropetal Technology as a comparable for ITeS due to its engagement in high-end engineering design services. M/s CG VAK Software and Exports Ltd was included as a comparable for ITeS despite persistent losses and not meeting the turnover filter. M/s R Systems Ltd was included as a comparable for ITeS, emphasizing challenges in comparing financial data with different year-ends. The allowance of ESOP discount as a deduction raised questions on ESOP expense treatment. The debate on comparables for benchmarking ALP highlighted the importance of functional similarity. The judgment emphasized the complexities in transfer pricing analysis and the need for accurate data and comparables selection. en-us Fri, 06 Jan 2023 00:00:00 +0530 Wed, 25 Jan 2023 17:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433342 The Tribunal directed the Assessing Officer to exclude M/s Acropetal Technology as a comparable for ITeS due to its engagement in high-end engineering design services. M/s CG VAK Software and Exports Ltd was included as a comparable for ITeS despite persistent losses and not meeting the turnover filter. M/s R Systems Ltd was included as a comparable for ITeS, emphasizing challenges in comparing financial data with different year-ends. The allowance of ESOP discount as a deduction raised questions on ESOP expense treatment. The debate on comparables for benchmarking ALP highlighted the importance of functional similarity. The judgment emphasized the complexities in transfer pricing analysis and the need for accurate data and comparables selection. Case-Laws Income Tax Fri, 06 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433342