https://www.taxtmi.com/caselaws?id=436053 The Tribunal partly allowed the appeal, directing the Assessing Officer to rework the arm's length price of the international transaction. Specific comparables were included or excluded based on detailed functional, asset, and risk analysis to ensure appropriate benchmarking. The Tribunal upheld the application of the 75% export filter for comparables, excluding companies with predominantly domestic sales. The provision for doubtful debts was considered an operating expense, impacting the margin calculation for CG-VAK Software and Exports Ltd. Nihilent Analytics Ltd. was excluded due to its significant asset base, which could affect margin comparability. Interest levy under Section 234B was deemed consequential. en-us Fri, 20 Jan 2023 00:00:00 +0530 Tue, 04 Apr 2023 08:29:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436053 The Tribunal partly allowed the appeal, directing the Assessing Officer to rework the arm's length price of the international transaction. Specific comparables were included or excluded based on detailed functional, asset, and risk analysis to ensure appropriate benchmarking. The Tribunal upheld the application of the 75% export filter for comparables, excluding companies with predominantly domestic sales. The provision for doubtful debts was considered an operating expense, impacting the margin calculation for CG-VAK Software and Exports Ltd. Nihilent Analytics Ltd. was excluded due to its significant asset base, which could affect margin comparability. Interest levy under Section 234B was deemed consequential. Case-Laws Income Tax Fri, 20 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436053