https://www.taxtmi.com/caselaws?id=461111 The ITAT Delhi ruled on transfer pricing adjustments and Section 10AA deductions. The tribunal directed exclusion of several companies from comparables including E-Infochips Bangalore Ltd (functionally dissimilar), Infinite Data Systems (insufficient segmental data), Persistent Systems Ltd (no segmental data), and others for various reasons including functional differences and lack of export activities. The tribunal upheld TPO's exclusion of PSI Data Systems and Crazy Infotech Ltd. Multiple year data usage was rejected absent specific justification. Working capital adjustment issue was remanded for fresh consideration. The tribunal allowed Section 10AA deduction, holding that cost-plus markup receipts from foreign associated enterprises constitute foreign currency receipts satisfying statutory requirements. en-us Wed, 22 Mar 2017 00:00:00 +0530 Thu, 13 Mar 2025 17:01:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461111 The ITAT Delhi ruled on transfer pricing adjustments and Section 10AA deductions. The tribunal directed exclusion of several companies from comparables including E-Infochips Bangalore Ltd (functionally dissimilar), Infinite Data Systems (insufficient segmental data), Persistent Systems Ltd (no segmental data), and others for various reasons including functional differences and lack of export activities. The tribunal upheld TPO's exclusion of PSI Data Systems and Crazy Infotech Ltd. Multiple year data usage was rejected absent specific justification. Working capital adjustment issue was remanded for fresh consideration. The tribunal allowed Section 10AA deduction, holding that cost-plus markup receipts from foreign associated enterprises constitute foreign currency receipts satisfying statutory requirements. Case-Laws Income Tax Wed, 22 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461111