https://www.taxtmi.com/caselaws?id=768728 ITAT Mumbai directed exclusion of Innovana Thinklabs Ltd. and K7 Computing Pvt Ltd from transfer pricing comparables as assessee was a limited risk reseller without plant, equipment, or intangible assets. Virtual Galaxy Infotech excluded for functional dissimilarity. Sonata Information Technology included after satisfying turnover filter. Several comparables remitted to AO/TPO for verification based on proper filters. Working capital adjustment and proportionate adjustments granted following precedent. For service segments, MT Education Services excluded due to turnover mismatch, while school-running companies excluded for functional dissimilarity. Cybercom Datamatics excluded lacking segmental details. MPS Ltd excluded as IT service provider rather than ITES provider. Tech Mahindra Business Services excluded due to brand value and functional differences. en-us Fri, 28 Feb 2025 00:00:00 +0530 Thu, 10 Apr 2025 14:45:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768728 ITAT Mumbai directed exclusion of Innovana Thinklabs Ltd. and K7 Computing Pvt Ltd from transfer pricing comparables as assessee was a limited risk reseller without plant, equipment, or intangible assets. Virtual Galaxy Infotech excluded for functional dissimilarity. Sonata Information Technology included after satisfying turnover filter. Several comparables remitted to AO/TPO for verification based on proper filters. Working capital adjustment and proportionate adjustments granted following precedent. For service segments, MT Education Services excluded due to turnover mismatch, while school-running companies excluded for functional dissimilarity. Cybercom Datamatics excluded lacking segmental details. MPS Ltd excluded as IT service provider rather than ITES provider. Tech Mahindra Business Services excluded due to brand value and functional differences. Case-Laws Income Tax Fri, 28 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768728