https://www.taxtmi.com/caselaws?id=459499 Delhi HC upheld ITAT's exclusion of three entities from transfer pricing comparables. L&T was excluded due to inability to bifurcate revenues from software development services versus products with precision. Wipro was rejected despite functional similarity because of tainted controlled transactions with related entity. Zylog was excluded for same reasons as L&T regarding revenue bifurcation issues. Court found no legal infirmity in ITAT's reasoning and determined no substantial question of law arose from the exclusions. en-us Fri, 22 Mar 2024 00:00:00 +0530 Tue, 17 Dec 2024 08:41:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459499 Delhi HC upheld ITAT's exclusion of three entities from transfer pricing comparables. L&T was excluded due to inability to bifurcate revenues from software development services versus products with precision. Wipro was rejected despite functional similarity because of tainted controlled transactions with related entity. Zylog was excluded for same reasons as L&T regarding revenue bifurcation issues. Court found no legal infirmity in ITAT's reasoning and determined no substantial question of law arose from the exclusions. Case-Laws Income Tax Fri, 22 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459499