https://www.taxtmi.com/caselaws?id=307459 The ITAT partly allowed the assessee's appeal for statistical purposes. It remitted the issue of Transfer Pricing Adjustment back to the Assessing Officer for fresh consideration, directing the exclusion of certain comparables in the software development segment due to functional dissimilarities and turnover filters. The Tribunal upheld the disallowance of software expenditure as capital expenditure, dismissing the appeal on this ground. It also directed the Assessing Officer to grant credit for taxes paid in protest after verification, allowing the appeal on this issue for statistical purposes. en-us Wed, 04 Mar 2020 00:00:00 +0530 Fri, 20 Feb 2026 17:21:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307459 The ITAT partly allowed the assessee's appeal for statistical purposes. It remitted the issue of Transfer Pricing Adjustment back to the Assessing Officer for fresh consideration, directing the exclusion of certain comparables in the software development segment due to functional dissimilarities and turnover filters. The Tribunal upheld the disallowance of software expenditure as capital expenditure, dismissing the appeal on this ground. It also directed the Assessing Officer to grant credit for taxes paid in protest after verification, allowing the appeal on this issue for statistical purposes. Case-Laws Income Tax Wed, 04 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307459