https://www.taxtmi.com/caselaws?id=768071 ITAT Mumbai held that several companies including Infosys Ltd, Persistent Systems Ltd, Tata Elexi Ltd, and Bodhtree Consulting Ltd should be excluded from transfer pricing benchmarking for software development services due to functional incomparability or lack of segmental data. The tribunal allowed Section 10A deductions for multiple units including UB Plaza and Titanium STPI units, following coordinate bench decisions. The depreciation on goodwill claim was remanded to AO for fresh consideration. Communication and travel expenses exclusion from turnover computation was upheld following SC precedent in HCL Technologies. Software disallowance under Section 40(a)(ia) deletion was sustained following Karnataka HC decision in Tally Solutions. en-us Tue, 25 Feb 2025 00:00:00 +0530 Mon, 31 Mar 2025 08:41:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768071 ITAT Mumbai held that several companies including Infosys Ltd, Persistent Systems Ltd, Tata Elexi Ltd, and Bodhtree Consulting Ltd should be excluded from transfer pricing benchmarking for software development services due to functional incomparability or lack of segmental data. The tribunal allowed Section 10A deductions for multiple units including UB Plaza and Titanium STPI units, following coordinate bench decisions. The depreciation on goodwill claim was remanded to AO for fresh consideration. Communication and travel expenses exclusion from turnover computation was upheld following SC precedent in HCL Technologies. Software disallowance under Section 40(a)(ia) deletion was sustained following Karnataka HC decision in Tally Solutions. Case-Laws Income Tax Tue, 25 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768071