https://www.taxtmi.com/caselaws?id=311911 ITAT Delhi ruled in favor of the assessee on two issues. First, regarding TP adjustment, the tribunal directed TPO to exclude five comparables (Aptico Ltd., Info Edge India Ltd., MMTV Ltd., TSR Darashaw Ltd., and Global Procurement Consultants Ltd.) as they were functionally dissimilar to the assessee's marketing, supervising and support services for mining/meteorological/metals minerals processing industry. Second, on TDS u/s 195, the tribunal dismissed Revenue's appeal, upholding that no tax deduction was required from payments to foreign entity as the payee was not liable to tax under DTAA provisions. en-us Wed, 23 Oct 2019 00:00:00 +0530 Sat, 20 Jan 2024 21:00:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311911 ITAT Delhi ruled in favor of the assessee on two issues. First, regarding TP adjustment, the tribunal directed TPO to exclude five comparables (Aptico Ltd., Info Edge India Ltd., MMTV Ltd., TSR Darashaw Ltd., and Global Procurement Consultants Ltd.) as they were functionally dissimilar to the assessee's marketing, supervising and support services for mining/meteorological/metals minerals processing industry. Second, on TDS u/s 195, the tribunal dismissed Revenue's appeal, upholding that no tax deduction was required from payments to foreign entity as the payee was not liable to tax under DTAA provisions. Case-Laws Income Tax Wed, 23 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311911