https://www.taxtmi.com/caselaws?id=451283 For determining ALP in the contract software development segment, the Tribunal held that a company lacking segmental data and engaged in broader software engineering services was not functionally comparable and directed its exclusion; a full-risk entity with marketing spend and intangibles was also held incomparable to a low-risk captive coder/tester and was excluded. A company earlier rejected as a persistent loss-maker was directed to be included since it earned profit in the relevant year; another single-segment software development company was held functionally similar and treated as comparable; and a functionally similar company affected by amalgamation was remanded for examining its impact on profitability before inclusion/exclusion. Notional interest on AE receivables and mismatch with Form 26AS were remanded for de novo adjudication, while the TCS short-credit ground was dismissed as impermissible parallel remedy. en-us Wed, 20 Mar 2024 00:00:00 +0530 Thu, 08 Jan 2026 13:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451283 For determining ALP in the contract software development segment, the Tribunal held that a company lacking segmental data and engaged in broader software engineering services was not functionally comparable and directed its exclusion; a full-risk entity with marketing spend and intangibles was also held incomparable to a low-risk captive coder/tester and was excluded. A company earlier rejected as a persistent loss-maker was directed to be included since it earned profit in the relevant year; another single-segment software development company was held functionally similar and treated as comparable; and a functionally similar company affected by amalgamation was remanded for examining its impact on profitability before inclusion/exclusion. Notional interest on AE receivables and mismatch with Form 26AS were remanded for de novo adjudication, while the TCS short-credit ground was dismissed as impermissible parallel remedy. Case-Laws Income Tax Wed, 20 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451283