https://www.taxtmi.com/caselaws?id=311538 ITAT Bangalore ruled on transfer pricing comparable selection, excluding multiple companies including Datamatics Business Solutions Ltd. (KPO company), Infosys BPM Services Pvt. Ltd. (functionally dissimilar with robotics automation), Manipal Digital Systems Pvt. Ltd., CES Ltd., and SPI Technologies India Pvt. Ltd. due to functional dissimilarity. BNR Udyog Ltd. was included as comparable. R Systems International Ltd. and Bhilwara Infotechnology Pvt. Ltd. were remitted to AO/TPO for fresh verification. Working capital adjustment was allowed following OECD guidelines. Issue regarding lease equalization cost treatment in operating markup computation was remitted to AO/TPO for examination of whether assessee claimed deduction. en-us Wed, 12 Jul 2023 00:00:00 +0530 Mon, 04 May 2026 14:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311538 ITAT Bangalore ruled on transfer pricing comparable selection, excluding multiple companies including Datamatics Business Solutions Ltd. (KPO company), Infosys BPM Services Pvt. Ltd. (functionally dissimilar with robotics automation), Manipal Digital Systems Pvt. Ltd., CES Ltd., and SPI Technologies India Pvt. Ltd. due to functional dissimilarity. BNR Udyog Ltd. was included as comparable. R Systems International Ltd. and Bhilwara Infotechnology Pvt. Ltd. were remitted to AO/TPO for fresh verification. Working capital adjustment was allowed following OECD guidelines. Issue regarding lease equalization cost treatment in operating markup computation was remitted to AO/TPO for examination of whether assessee claimed deduction. Case-Laws Income Tax Wed, 12 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311538