https://www.taxtmi.com/caselaws?id=461502 ITAT Delhi upheld TPO's exclusion of several comparables including Caliber Point Business Solutions Ltd. and R. Systems International Ltd. due to different financial year-ends and data reliability issues, applying Rule 10B(4) and Rule 10C(2)(c). BNR Udyog Ltd., E-Clerx Services Ltd., Infosys BPO Ltd., and TCS E-serve Ltd. were excluded for providing non-comparable services or having different business models. However, following Delhi HC's Kusum Healthcare precedent, ITAT allowed assessee's appeal on interest adjustment for inter-company receivables, noting receivables' impact was already factored in working capital pricing. Foreign tax credit and MAT credit matters were remanded for verification. en-us Thu, 17 Mar 2022 00:00:00 +0530 Wed, 09 Apr 2025 13:23:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461502 ITAT Delhi upheld TPO's exclusion of several comparables including Caliber Point Business Solutions Ltd. and R. Systems International Ltd. due to different financial year-ends and data reliability issues, applying Rule 10B(4) and Rule 10C(2)(c). BNR Udyog Ltd., E-Clerx Services Ltd., Infosys BPO Ltd., and TCS E-serve Ltd. were excluded for providing non-comparable services or having different business models. However, following Delhi HC's Kusum Healthcare precedent, ITAT allowed assessee's appeal on interest adjustment for inter-company receivables, noting receivables' impact was already factored in working capital pricing. Foreign tax credit and MAT credit matters were remanded for verification. Case-Laws Income Tax Thu, 17 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461502