https://www.taxtmi.com/caselaws?id=439300 In transfer pricing adjustment for software development services, the ITAT held that the related party transactions (RPT) ratio for comparables must be computed consistently on an aggregate basis as (RPT income + RPT expenses) ÷ sales, and directed the AO to recompute accordingly. It affirmed adoption of a 15% RPT filter as judicially upheld, and required fresh verification for certain comparables where functional profile, segmental data, or AY-consistency required examination; comparables lacking reliable financial reporting were to be excluded. It upheld exclusion of an ITeS company as not comparable to software development services, directed inclusion of one functionally comparable company, remanded issues on another company's inclusion and correction of an incorrect comparable margin, and allowed working capital adjustment in line with OECD-based comparability principles. en-us Fri, 16 Jun 2023 00:00:00 +0530 Mon, 05 Jan 2026 12:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439300 In transfer pricing adjustment for software development services, the ITAT held that the related party transactions (RPT) ratio for comparables must be computed consistently on an aggregate basis as (RPT income + RPT expenses) ÷ sales, and directed the AO to recompute accordingly. It affirmed adoption of a 15% RPT filter as judicially upheld, and required fresh verification for certain comparables where functional profile, segmental data, or AY-consistency required examination; comparables lacking reliable financial reporting were to be excluded. It upheld exclusion of an ITeS company as not comparable to software development services, directed inclusion of one functionally comparable company, remanded issues on another company's inclusion and correction of an incorrect comparable margin, and allowed working capital adjustment in line with OECD-based comparability principles. Case-Laws Income Tax Fri, 16 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439300