https://www.taxtmi.com/caselaws?id=433732 The Tribunal directed the exclusion of high-turnover companies from comparables, remanded the inclusion of Akshay Software Technologies Ltd. for fresh consideration, and instructed a re-examination of the working capital adjustment. It upheld the disallowance of the short-term capital loss on investment transfer and directed the deletion of disallowance under Section 40(a)(ia) for non-deduction of TDS on management fees, emphasizing adherence to DTAA provisions and functional profile examination. en-us Mon, 28 Nov 2022 00:00:00 +0530 Wed, 08 Feb 2023 11:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433732 The Tribunal directed the exclusion of high-turnover companies from comparables, remanded the inclusion of Akshay Software Technologies Ltd. for fresh consideration, and instructed a re-examination of the working capital adjustment. It upheld the disallowance of the short-term capital loss on investment transfer and directed the deletion of disallowance under Section 40(a)(ia) for non-deduction of TDS on management fees, emphasizing adherence to DTAA provisions and functional profile examination. Case-Laws Income Tax Mon, 28 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433732