https://www.taxtmi.com/highlights?id=89695 ITAT ruled on transfer pricing comparable selection for appellant engaged in software development services to associated enterprise on cost-plus markup basis. Tribunal excluded six companies from comparables: Tata Elxsi Limited due to diversified activities including animation/VFX services creating functional dissimilarity; Persistent Systems Limited for functional dissimilarity and being giant company; Aspire Systems for extraordinary amalgamation event and turnover filter; Infosys Limited as captive service provider incomparable to appellant's cost-plus model; Thirdware Solutions for functional differences and intangible asset ownership; Cybage Software for providing different services. However, Larsen & Toubro Infotech Limited and Infobe..... en-us Mon, 23 Jun 2025 08:43:03 +0530 Mon, 23 Jun 2025 08:43:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=89695 ITAT ruled on transfer pricing comparable selection for appellant engaged in software development services to associated enterprise on cost-plus markup basis. Tribunal excluded six companies from comparables: Tata Elxsi Limited due to diversified activities including animation/VFX services creating functional dissimilarity; Persistent Systems Limited for functional dissimilarity and being giant company; Aspire Systems for extraordinary amalgamation event and turnover filter; Infosys Limited as captive service provider incomparable to appellant's cost-plus model; Thirdware Solutions for functional differences and intangible asset ownership; Cybage Software for providing different services. However, Larsen & Toubro Infotech Limited and Infobe..... Highlights Income Tax Mon, 23 Jun 2025 08:43:03 +0530 https://www.taxtmi.com/highlights?id=89695