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    <title>2023 (3) TMI 1564 - ITAT DELHI</title>
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    <description>ITAT Delhi allowed the appeal partially regarding TP adjustments. The tribunal rejected TPO&#039;s allocation of operating costs between AE and non-AE segments based on turnover, accepting assessee&#039;s segmental profitability computation since separate employee accounts were maintained. For comparable selection, Korus Engineering Solutions was excluded due to insufficient functional profile information, while TCE Consulting Engineers was retained despite low export turnover as no export filter was applied. Onward Technologies&#039; exclusion for RPT exceeding 25% was remanded to AO for examination. Working capital adjustment and computational error issues were also remanded for fresh consideration with proper hearing opportunity.</description>
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      <title>2023 (3) TMI 1564 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=461085</link>
      <description>ITAT Delhi allowed the appeal partially regarding TP adjustments. The tribunal rejected TPO&#039;s allocation of operating costs between AE and non-AE segments based on turnover, accepting assessee&#039;s segmental profitability computation since separate employee accounts were maintained. For comparable selection, Korus Engineering Solutions was excluded due to insufficient functional profile information, while TCE Consulting Engineers was retained despite low export turnover as no export filter was applied. Onward Technologies&#039; exclusion for RPT exceeding 25% was remanded to AO for examination. Working capital adjustment and computational error issues were also remanded for fresh consideration with proper hearing opportunity.</description>
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