https://www.taxtmi.com/caselaws?id=310123 The Tribunal partly allowed the appeal, upholding the validity of the assessment order and rejection of transfer pricing documentation. It directed the exclusion of certain companies in the comparability analysis for SWD, ITeS, and MSS segments based on turnover filters. The Tribunal also ordered working capital adjustments for comparable companies and affirmed the treatment of forex as operating in nature. The issue of interest on outstanding receivables was remitted for re-evaluation, and the levy of interest under sections 234B and 234D was upheld. Penalty proceedings initiation was deemed procedural. The Tribunal stressed the importance of functional comparability and appropriate adjustments in transfer pricing analysis. en-us Thu, 30 Mar 2023 00:00:00 +0530 Sat, 07 Oct 2023 08:32:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310123 The Tribunal partly allowed the appeal, upholding the validity of the assessment order and rejection of transfer pricing documentation. It directed the exclusion of certain companies in the comparability analysis for SWD, ITeS, and MSS segments based on turnover filters. The Tribunal also ordered working capital adjustments for comparable companies and affirmed the treatment of forex as operating in nature. The issue of interest on outstanding receivables was remitted for re-evaluation, and the levy of interest under sections 234B and 234D was upheld. Penalty proceedings initiation was deemed procedural. The Tribunal stressed the importance of functional comparability and appropriate adjustments in transfer pricing analysis. Case-Laws Income Tax Thu, 30 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310123