https://www.taxtmi.com/caselaws?id=446952 Functionally dissimilar transfer pricing comparables with no reliable segmental data were excluded because software development, engineering design, geospatial consulting and high-end KPO functions were not comparable to a low-end BPO service provider; Acropetal Technology Ltd., Eclerx Services Pvt. Ltd., Genesys International Corporation Ltd. and ICRA Techno Analytics Ltd. were excluded, while Infinity.com Financial Securities Ltd. was retained. The working capital adjustment claim was remitted for verification in light of the assessee's business model and past-year treatment. Management fee paid to the overseas associated enterprise was held to be for general managerial services not taxable in India under the applicable treaty, so no withholding obligation arose and the disallowance under section 40(a)(i) was deleted. en-us Wed, 29 Nov 2023 00:00:00 +0530 Fri, 15 Dec 2023 08:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446952 Functionally dissimilar transfer pricing comparables with no reliable segmental data were excluded because software development, engineering design, geospatial consulting and high-end KPO functions were not comparable to a low-end BPO service provider; Acropetal Technology Ltd., Eclerx Services Pvt. Ltd., Genesys International Corporation Ltd. and ICRA Techno Analytics Ltd. were excluded, while Infinity.com Financial Securities Ltd. was retained. The working capital adjustment claim was remitted for verification in light of the assessee's business model and past-year treatment. Management fee paid to the overseas associated enterprise was held to be for general managerial services not taxable in India under the applicable treaty, so no withholding obligation arose and the disallowance under section 40(a)(i) was deleted. Case-Laws Income Tax Wed, 29 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446952