https://www.taxtmi.com/caselaws?id=761691 The ITAT Chennai ruled on transfer pricing adjustments for a software solutions provider. The tribunal directed exclusion of several comparables: Kals Information Systems Ltd due to functional and segmental differences, Infosys Technology Ltd for incomparable size exceeding 10 times turnover threshold, Bodh Tree Consulting Ltd for revenue source differences, and Sonata Software Ltd for failing the 25% related party transaction filter. The tribunal granted working capital adjustment entitlement and restored computation issues to AO/TPO. Regarding Section 14A disallowance, the tribunal confirmed disallowance but directed verification of interest-free funds availability. Section 10A deduction computation issues were restored to AO/DRP for fact verification, and refund interest charging under Section 234D was remanded for AO verification. en-us Fri, 10 May 2024 00:00:00 +0530 Mon, 11 Nov 2024 10:54:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761691 The ITAT Chennai ruled on transfer pricing adjustments for a software solutions provider. The tribunal directed exclusion of several comparables: Kals Information Systems Ltd due to functional and segmental differences, Infosys Technology Ltd for incomparable size exceeding 10 times turnover threshold, Bodh Tree Consulting Ltd for revenue source differences, and Sonata Software Ltd for failing the 25% related party transaction filter. The tribunal granted working capital adjustment entitlement and restored computation issues to AO/TPO. Regarding Section 14A disallowance, the tribunal confirmed disallowance but directed verification of interest-free funds availability. Section 10A deduction computation issues were restored to AO/DRP for fact verification, and refund interest charging under Section 234D was remanded for AO verification. Case-Laws Income Tax Fri, 10 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761691