https://www.taxtmi.com/caselaws?id=447178 ITAT Bangalore directed TPO to exclude Tech Mahindra Business Services Ltd. and Infosys BPM Services Pvt. Ltd. from comparable selection due to turnover exceeding Rs. 200 crores filter. Regarding assets received free from associated enterprises, tribunal held capitalization was correct but directed depreciation consideration only under software development segment to avoid double disallowance. Multiple comparables were rejected for functional dissimilarity or lack of segmental information. Matter remanded for fresh comparable selection under software development segment with proper opportunity to assessee. Outstanding receivables issue remanded following Special Bench precedent treating it as international transaction. Seconded employee salary reimbursement and bonding expenses issues also remanded for fresh consideration with proper evidence evaluation. en-us Fri, 13 Oct 2023 00:00:00 +0530 Tue, 19 Dec 2023 18:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447178 ITAT Bangalore directed TPO to exclude Tech Mahindra Business Services Ltd. and Infosys BPM Services Pvt. Ltd. from comparable selection due to turnover exceeding Rs. 200 crores filter. Regarding assets received free from associated enterprises, tribunal held capitalization was correct but directed depreciation consideration only under software development segment to avoid double disallowance. Multiple comparables were rejected for functional dissimilarity or lack of segmental information. Matter remanded for fresh comparable selection under software development segment with proper opportunity to assessee. Outstanding receivables issue remanded following Special Bench precedent treating it as international transaction. Seconded employee salary reimbursement and bonding expenses issues also remanded for fresh consideration with proper evidence evaluation. Case-Laws Income Tax Fri, 13 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447178