https://www.taxtmi.com/caselaws?id=307862 The Tribunal partly allowed the appeal, directing reconsideration of transfer pricing adjustments in the manufacturing and software development services segments. It remanded the issues of capacity utilization, customs duty, exchange rate fluctuations, and comparables for fresh consideration. The Tribunal excluded certain comparables and allowed working capital adjustments in the SWD segment. It permitted the provision for warranty but remanded the disallowance of annual license fees for further examination. The Tribunal instructed the AO to verify and consider the set-off of brought forward losses. Overall, detailed directions were given for proper evaluation and adjudication of the issues. en-us Tue, 29 Mar 2022 00:00:00 +0530 Fri, 12 May 2023 21:13:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307862 The Tribunal partly allowed the appeal, directing reconsideration of transfer pricing adjustments in the manufacturing and software development services segments. It remanded the issues of capacity utilization, customs duty, exchange rate fluctuations, and comparables for fresh consideration. The Tribunal excluded certain comparables and allowed working capital adjustments in the SWD segment. It permitted the provision for warranty but remanded the disallowance of annual license fees for further examination. The Tribunal instructed the AO to verify and consider the set-off of brought forward losses. Overall, detailed directions were given for proper evaluation and adjudication of the issues. Case-Laws Income Tax Tue, 29 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307862