https://www.taxtmi.com/caselaws?id=312376 The ITAT Bangalore directed the TPO to exclude five companies from comparables in the ITES segment for ALP determination, finding them functionally dissimilar to the assessee. The tribunal dismissed the appeal regarding negative working capital adjustment, upholding the TPO's computation of 36.81% adjusted margin. On TDS under section 40(a)(ia) for software expenses, the matter was restored to the AO for verification of tax payment by recipients. Similarly, the issue of loyalty bonus provision in book profit computation under section 115JB was remanded to the AO for verification, following a coordinate bench decision in the assessee's own case. en-us Tue, 30 Jun 2020 00:00:00 +0530 Wed, 14 Feb 2024 05:25:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312376 The ITAT Bangalore directed the TPO to exclude five companies from comparables in the ITES segment for ALP determination, finding them functionally dissimilar to the assessee. The tribunal dismissed the appeal regarding negative working capital adjustment, upholding the TPO's computation of 36.81% adjusted margin. On TDS under section 40(a)(ia) for software expenses, the matter was restored to the AO for verification of tax payment by recipients. Similarly, the issue of loyalty bonus provision in book profit computation under section 115JB was remanded to the AO for verification, following a coordinate bench decision in the assessee's own case. Case-Laws Income Tax Tue, 30 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312376