https://www.taxtmi.com/caselaws?id=310584 ITAT Bangalore remanded transfer pricing matter to AO/TPO for fresh determination after finding TPO used data from incorrect financial years for three comparable companies instead of relevant FY 2002-03. Tribunal directed AO/TPO to obtain proper FY 2002-03 data, including compilation from quarterly reports if necessary. Issue regarding Satyam Computer Services comparability also remanded for factual verification of account falsification. Section 10A deduction matter restored to AO due to insufficient examination of nexus between interest income and business undertaking. Revenue's appeal on cost suppression allowed for statistical purposes, requiring fresh decision on administrative services received free from associated enterprise while excluding ESOP value. Assessee's ground on total turnover computation rejected, upholding CIT(A)'s direction to reduce communication charges. en-us Fri, 21 Apr 2017 00:00:00 +0530 Wed, 01 Nov 2023 21:07:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310584 ITAT Bangalore remanded transfer pricing matter to AO/TPO for fresh determination after finding TPO used data from incorrect financial years for three comparable companies instead of relevant FY 2002-03. Tribunal directed AO/TPO to obtain proper FY 2002-03 data, including compilation from quarterly reports if necessary. Issue regarding Satyam Computer Services comparability also remanded for factual verification of account falsification. Section 10A deduction matter restored to AO due to insufficient examination of nexus between interest income and business undertaking. Revenue's appeal on cost suppression allowed for statistical purposes, requiring fresh decision on administrative services received free from associated enterprise while excluding ESOP value. Assessee's ground on total turnover computation rejected, upholding CIT(A)'s direction to reduce communication charges. Case-Laws Income Tax Fri, 21 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310584