https://www.taxtmi.com/caselaws?id=771126 ITAT Mumbai ruled in favor of the assessee in a transfer pricing dispute, directing exclusion of seven comparables selected by the TPO. The excluded companies were MPS Ltd (significant R&D activities, no segmental data), IRIS Business Services Ltd (multiple service lines without segmental bifurcation), Omega Healthcare Management Services (100% related party transactions), ICRA Techno Analytics Ltd (RPT exceeding 25%, limited segmental data), eClerx Services Ltd (functionally distinct KPO operations), Infobeans Technologies Ltd (mixed revenue streams without segmental data), and Thirdware Solutions Ltd (high-end software development). After exclusions, remaining comparables' margins aligned with assessee's declared margins, proving arm's length pricing. ITAT directed AO to recompute ALP and deleted additions under Section 92CA(3). en-us Thu, 08 May 2025 00:00:00 +0530 Mon, 19 May 2025 15:28:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771126 ITAT Mumbai ruled in favor of the assessee in a transfer pricing dispute, directing exclusion of seven comparables selected by the TPO. The excluded companies were MPS Ltd (significant R&D activities, no segmental data), IRIS Business Services Ltd (multiple service lines without segmental bifurcation), Omega Healthcare Management Services (100% related party transactions), ICRA Techno Analytics Ltd (RPT exceeding 25%, limited segmental data), eClerx Services Ltd (functionally distinct KPO operations), Infobeans Technologies Ltd (mixed revenue streams without segmental data), and Thirdware Solutions Ltd (high-end software development). After exclusions, remaining comparables' margins aligned with assessee's declared margins, proving arm's length pricing. ITAT directed AO to recompute ALP and deleted additions under Section 92CA(3). Case-Laws Income Tax Thu, 08 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771126