https://www.taxtmi.com/caselaws?id=306407 The Tribunal partially allowed the appeal, directing the Transfer Pricing Officer (TPO) to recompute the Arm's Length Price (ALP) for Software Development Services. The TPO/AO were instructed to exclude certain high-turnover comparables and allow adjustments for working capital, risk, and capacity utilization. The issue of selecting the foreign Associated Enterprise (AE) as the tested party was remanded for fresh consideration, with reference to OECD guidelines and the UN TP Manual. en-us Mon, 20 Dec 2021 00:00:00 +0530 Fri, 27 Jan 2023 20:17:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306407 The Tribunal partially allowed the appeal, directing the Transfer Pricing Officer (TPO) to recompute the Arm's Length Price (ALP) for Software Development Services. The TPO/AO were instructed to exclude certain high-turnover comparables and allow adjustments for working capital, risk, and capacity utilization. The issue of selecting the foreign Associated Enterprise (AE) as the tested party was remanded for fresh consideration, with reference to OECD guidelines and the UN TP Manual. Case-Laws Income Tax Mon, 20 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306407