https://www.taxtmi.com/caselaws?id=447179 ITAT Bangalore directed computation of transfer pricing margin per APA agreement terms at 18% for ITeS segment services. Tribunal excluded CRA Online Ltd. as comparable due to functional dissimilarity but retained Cosmic Global Ltd. since revenue did not dispute functionality. For Informed Technologies India Ltd. and Inhouse Production Ltd., AO/TPO directed to verify details from annual reports before exclusion. Regarding depreciation on goodwill, AO instructed to consider assessee's claim following SC precedent in CIT vs. Smifs Securities Ltd. Case remanded for fresh determination of arms length price under APA methodology. en-us Fri, 13 Oct 2023 00:00:00 +0530 Wed, 20 Dec 2023 09:37:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447179 ITAT Bangalore directed computation of transfer pricing margin per APA agreement terms at 18% for ITeS segment services. Tribunal excluded CRA Online Ltd. as comparable due to functional dissimilarity but retained Cosmic Global Ltd. since revenue did not dispute functionality. For Informed Technologies India Ltd. and Inhouse Production Ltd., AO/TPO directed to verify details from annual reports before exclusion. Regarding depreciation on goodwill, AO instructed to consider assessee's claim following SC precedent in CIT vs. Smifs Securities Ltd. Case remanded for fresh determination of arms length price under APA methodology. Case-Laws Income Tax Fri, 13 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447179