https://www.taxtmi.com/caselaws?id=310986 The ITAT Delhi upheld the CIT(A)'s exclusion of Alphageo (India) Ltd. as a comparable for transfer pricing due to significant differences in employee cost ratios (7.55% vs 60.35%) and export turnover failing the 25% threshold filter. The tribunal allowed miscellaneous income from notice period pay recovery to be included in Section 10B deduction computation, distinguishing it from Liberty India SC precedent which applied only to DEPP/Duty Drawback benefits. Additionally, Stup Consultants Pvt. Ltd. was excluded as a comparable due to functional dissimilarity, lack of segmental information, and failing export filter criteria. The revenue's appeal was dismissed. en-us Mon, 15 Apr 2019 00:00:00 +0530 Thu, 30 Nov 2023 18:01:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310986 The ITAT Delhi upheld the CIT(A)'s exclusion of Alphageo (India) Ltd. as a comparable for transfer pricing due to significant differences in employee cost ratios (7.55% vs 60.35%) and export turnover failing the 25% threshold filter. The tribunal allowed miscellaneous income from notice period pay recovery to be included in Section 10B deduction computation, distinguishing it from Liberty India SC precedent which applied only to DEPP/Duty Drawback benefits. Additionally, Stup Consultants Pvt. Ltd. was excluded as a comparable due to functional dissimilarity, lack of segmental information, and failing export filter criteria. The revenue's appeal was dismissed. Case-Laws Income Tax Mon, 15 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310986