https://www.taxtmi.com/caselaws?id=307517 The Tribunal partly allowed the appeal, directing the TPO/AO to compute the Arm's Length Price (ALP) for the international transaction of Software Development services in accordance with its directions. The decision stressed the exclusion of high-turnover companies from the comparable set, the necessity of working capital adjustments, and the requirement for reliable quantification in risk adjustments. The Tribunal remanded the inclusion of certain companies for fresh consideration and upheld the treatment of foreign exchange gains/losses as operating in nature. en-us Thu, 18 Nov 2021 00:00:00 +0530 Wed, 19 Apr 2023 21:28:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307517 The Tribunal partly allowed the appeal, directing the TPO/AO to compute the Arm's Length Price (ALP) for the international transaction of Software Development services in accordance with its directions. The decision stressed the exclusion of high-turnover companies from the comparable set, the necessity of working capital adjustments, and the requirement for reliable quantification in risk adjustments. The Tribunal remanded the inclusion of certain companies for fresh consideration and upheld the treatment of foreign exchange gains/losses as operating in nature. Case-Laws Income Tax Thu, 18 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307517