https://www.taxtmi.com/caselaws?id=439033 ITAT allowed the assessee's transfer pricing appeal in part by directing exclusion of multiple functionally dissimilar companies (including large, full-fledged software product and diversified IT service providers) from the final set of comparables, following its own orders for earlier years and consistent coordinate bench rulings. One proposed comparable was remitted to AO/TPO for fresh examination of functional similarity, and another software testing entity was also remanded to AO/TPO to verify comparability with a pure software development service provider. On disallowance under s.40(a)(i) relating to seconded employees, ITAT remanded the matter to AO to re-examine, in light of the jurisdictional HC ruling, whether complete tax deduction under s.192 had been made, in which event no disallowance under s.40(a)(i) would survive. en-us Thu, 08 Jun 2023 00:00:00 +0530 Mon, 08 Dec 2025 17:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439033 ITAT allowed the assessee's transfer pricing appeal in part by directing exclusion of multiple functionally dissimilar companies (including large, full-fledged software product and diversified IT service providers) from the final set of comparables, following its own orders for earlier years and consistent coordinate bench rulings. One proposed comparable was remitted to AO/TPO for fresh examination of functional similarity, and another software testing entity was also remanded to AO/TPO to verify comparability with a pure software development service provider. On disallowance under s.40(a)(i) relating to seconded employees, ITAT remanded the matter to AO to re-examine, in light of the jurisdictional HC ruling, whether complete tax deduction under s.192 had been made, in which event no disallowance under s.40(a)(i) would survive. Case-Laws Income Tax Thu, 08 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439033