https://www.taxtmi.com/caselaws?id=764836 The ITAT Mumbai ruled on transfer pricing adjustments for international transactions involving production and software development services. The tribunal excluded Universal Print Systems Limited and BNR Udyog Limited from comparables due to functional dissimilarity with the assessee's business profile. For software development services, Vama Industries Limited and Spry Resources India Pvt. Ltd. were excluded as comparables since IT and ITeS services are not comparable. The matter regarding Thirdware Solutions Ltd. was remanded to the TPO for explanation of margin computation methodology and re-determination of its inclusion/exclusion as a comparable after providing adequate hearing opportunity to the assessee. en-us Fri, 03 Jan 2025 00:00:00 +0530 Sat, 18 Jan 2025 11:26:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764836 The ITAT Mumbai ruled on transfer pricing adjustments for international transactions involving production and software development services. The tribunal excluded Universal Print Systems Limited and BNR Udyog Limited from comparables due to functional dissimilarity with the assessee's business profile. For software development services, Vama Industries Limited and Spry Resources India Pvt. Ltd. were excluded as comparables since IT and ITeS services are not comparable. The matter regarding Thirdware Solutions Ltd. was remanded to the TPO for explanation of margin computation methodology and re-determination of its inclusion/exclusion as a comparable after providing adequate hearing opportunity to the assessee. Case-Laws Income Tax Fri, 03 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764836