https://www.taxtmi.com/caselaws?id=435212 The ITAT Bangalore upheld exclusion of comparables with high turnover and those functionally dissimilar to the assessee in the transfer pricing analysis, directing AO/TPO to exclude specified companies. Incorrect margin computations by TPO were set aside, with directions to recompute margins correctly. ESOP expenses were not to be treated as operating costs since no cost was charged to the assessee and employees bore the tax liability. The Tribunal directed granting of working capital adjustment consistent with its earlier rulings. Regarding delayed PF remittance, the Tribunal followed the SC decision in Checkmate Services, confirming that employer contributions must be paid by the statutory due date for deductibility under section 43B, dismissing the assessee's challenge. Overall, the appeal was partly allowed on comparables and margin computation but dismissed on PF remittance. en-us Fri, 18 Nov 2022 00:00:00 +0530 Wed, 13 Aug 2025 12:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435212 The ITAT Bangalore upheld exclusion of comparables with high turnover and those functionally dissimilar to the assessee in the transfer pricing analysis, directing AO/TPO to exclude specified companies. Incorrect margin computations by TPO were set aside, with directions to recompute margins correctly. ESOP expenses were not to be treated as operating costs since no cost was charged to the assessee and employees bore the tax liability. The Tribunal directed granting of working capital adjustment consistent with its earlier rulings. Regarding delayed PF remittance, the Tribunal followed the SC decision in Checkmate Services, confirming that employer contributions must be paid by the statutory due date for deductibility under section 43B, dismissing the assessee's challenge. Overall, the appeal was partly allowed on comparables and margin computation but dismissed on PF remittance. Case-Laws Income Tax Fri, 18 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435212