https://www.taxtmi.com/caselaws?id=460038 The ITAT Ahmedabad ruled on a transfer pricing adjustment case involving software development services to associate enterprises. The tribunal partially accepted the assessee's appeal, directing the TPO to exclude Bodhtree Consulting Ltd from comparables due to functional differences, as it provides software products rather than development services. However, the tribunal rejected arguments against including Compu Learn India Tech Ltd, noting its PLI of 88.83% remained valid. The TPO was directed to conduct proper inquiry under rule 10B(3) and consider working capital adjustments while providing adequate hearing opportunity. en-us Fri, 29 Jul 2016 00:00:00 +0530 Wed, 08 Jan 2025 15:33:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460038 The ITAT Ahmedabad ruled on a transfer pricing adjustment case involving software development services to associate enterprises. The tribunal partially accepted the assessee's appeal, directing the TPO to exclude Bodhtree Consulting Ltd from comparables due to functional differences, as it provides software products rather than development services. However, the tribunal rejected arguments against including Compu Learn India Tech Ltd, noting its PLI of 88.83% remained valid. The TPO was directed to conduct proper inquiry under rule 10B(3) and consider working capital adjustments while providing adequate hearing opportunity. Case-Laws Income Tax Fri, 29 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460038