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    <title>2022 (7) TMI 1579 - ITAT BANGALORE</title>
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    <description>ITAT Bangalore ruled on transfer pricing adjustments involving expense reallocation and comparable selection. The TPO was directed to follow DRP directions regarding reallocation of expenses between software development, marketing support, and data center segments per section 144C(13). Multiple comparables were excluded due to high turnover disparity with the captive service provider or functional dissimilarity, including Tata Elxi, Mindtree, L&amp;amp;T Infotech, and others. Issues regarding Inteq Software and Aspire Systems were remanded for fresh consideration. The assessee was granted working capital adjustment entitlement. Three MSS segment comparables were excluded as functionally incomparable with the captive service provider&#039;s operations.</description>
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    <pubDate>Fri, 29 Jul 2022 00:00:00 +0530</pubDate>
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      <title>2022 (7) TMI 1579 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=461014</link>
      <description>ITAT Bangalore ruled on transfer pricing adjustments involving expense reallocation and comparable selection. The TPO was directed to follow DRP directions regarding reallocation of expenses between software development, marketing support, and data center segments per section 144C(13). Multiple comparables were excluded due to high turnover disparity with the captive service provider or functional dissimilarity, including Tata Elxi, Mindtree, L&amp;amp;T Infotech, and others. Issues regarding Inteq Software and Aspire Systems were remanded for fresh consideration. The assessee was granted working capital adjustment entitlement. Three MSS segment comparables were excluded as functionally incomparable with the captive service provider&#039;s operations.</description>
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      <pubDate>Fri, 29 Jul 2022 00:00:00 +0530</pubDate>
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