https://www.taxtmi.com/caselaws?id=757463 The ITAT Mumbai ruled on multiple transfer pricing and tax issues. The tribunal directed exclusion of eight companies from comparable selection due to functional dissimilarity for software development services benchmarking. Regarding interest on receivables, the case was remanded to TPO to compute outstanding amounts beyond grace periods for each invoice and determine appropriate grace periods based on agreements or market practice. The tribunal disallowed employee PF contribution deduction following SC precedent in Checkmate Services case for non-compliance with deposit timelines. Addition of capital reserve from merger was deleted as it doesn't constitute capital gains under section 47(vi). Finance cost disallowance was partially allowed, deleting interest on receivables from one AE. The AO was directed to examine double addition claims and provide advance tax/TDS credits for merged entity. en-us Tue, 13 Feb 2024 00:00:00 +0530 Sat, 24 Aug 2024 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757463 The ITAT Mumbai ruled on multiple transfer pricing and tax issues. The tribunal directed exclusion of eight companies from comparable selection due to functional dissimilarity for software development services benchmarking. Regarding interest on receivables, the case was remanded to TPO to compute outstanding amounts beyond grace periods for each invoice and determine appropriate grace periods based on agreements or market practice. The tribunal disallowed employee PF contribution deduction following SC precedent in Checkmate Services case for non-compliance with deposit timelines. Addition of capital reserve from merger was deleted as it doesn't constitute capital gains under section 47(vi). Finance cost disallowance was partially allowed, deleting interest on receivables from one AE. The AO was directed to examine double addition claims and provide advance tax/TDS credits for merged entity. Case-Laws Income Tax Tue, 13 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757463