https://www.taxtmi.com/caselaws?id=756839 ITAT Hyderabad ruled on transfer pricing adjustments regarding comparable company selection for software development services. The tribunal directed inclusion of Evoke Technologies Ltd, finding its functional analysis similar to the appellant's software development services. The tribunal also ordered inclusion of Akshay Software Technologies Ltd, Mindtree Ltd, and R.S. Software India Ltd, holding that DRP erred in suo moto applying onsite revenue filters without establishing higher costs. However, the tribunal directed exclusion of Persistent Systems Ltd and Sasken Communication Technologies Ltd, finding them not comparable as they were predominantly product companies rather than software development service providers operating on cost-plus markup basis. en-us Wed, 07 Aug 2024 00:00:00 +0530 Fri, 09 Aug 2024 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756839 ITAT Hyderabad ruled on transfer pricing adjustments regarding comparable company selection for software development services. The tribunal directed inclusion of Evoke Technologies Ltd, finding its functional analysis similar to the appellant's software development services. The tribunal also ordered inclusion of Akshay Software Technologies Ltd, Mindtree Ltd, and R.S. Software India Ltd, holding that DRP erred in suo moto applying onsite revenue filters without establishing higher costs. However, the tribunal directed exclusion of Persistent Systems Ltd and Sasken Communication Technologies Ltd, finding them not comparable as they were predominantly product companies rather than software development service providers operating on cost-plus markup basis. Case-Laws Income Tax Wed, 07 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756839