https://www.taxtmi.com/caselaws?id=446294 ITAT Delhi ruled on transfer pricing adjustments for an automotive component manufacturer providing software development and business support services. The tribunal excluded multiple comparables including E-Infochips, Infosys, Thirdware Solutions, Persistent Systems, E-Zest, Tata Elxsi, Alphageo India, Mitcon Consultancy, HCCA Business, and Cyber Media Online due to functional incomparability, lack of segmental data, or engagement in high-end services versus the assessee's low-risk captive services. The tribunal deleted TPO's benchmarking of fixed asset imports as no prescribed method under section 92C was followed. Regarding delayed receivables, the matter was restored to AO/TPO for fresh adjudication after admitting additional evidence. Appeal was partly allowed for statistical purposes. en-us Mon, 09 Oct 2023 00:00:00 +0530 Wed, 06 Mar 2024 16:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446294 ITAT Delhi ruled on transfer pricing adjustments for an automotive component manufacturer providing software development and business support services. The tribunal excluded multiple comparables including E-Infochips, Infosys, Thirdware Solutions, Persistent Systems, E-Zest, Tata Elxsi, Alphageo India, Mitcon Consultancy, HCCA Business, and Cyber Media Online due to functional incomparability, lack of segmental data, or engagement in high-end services versus the assessee's low-risk captive services. The tribunal deleted TPO's benchmarking of fixed asset imports as no prescribed method under section 92C was followed. Regarding delayed receivables, the matter was restored to AO/TPO for fresh adjudication after admitting additional evidence. Appeal was partly allowed for statistical purposes. Case-Laws Income Tax Mon, 09 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446294