https://www.taxtmi.com/caselaws?id=462485 The ITAT Mumbai ruled on transfer pricing adjustments and section 14A disallowance. Regarding comparable selection for ITES services, the tribunal restored R Systems International to AO/TPO for fresh examination despite different accounting year, as matching period data was available. However, it directed exclusion of Infosys BPO Ltd due to specialized services commanding premium pricing versus assessee's low-end back office support, and MPS Ltd for providing different services like content creation and platform development. The tribunal also restored working capital and risk adjustment issues to AO/TPO. For section 14A disallowance, it rejected Rule 8D application, accepting assessee's alternative computation of Rs. 5,52,490 based on proportionate expense allocation between business and exempt income. en-us Thu, 18 Aug 2022 00:00:00 +0530 Wed, 25 Jun 2025 19:01:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462485 The ITAT Mumbai ruled on transfer pricing adjustments and section 14A disallowance. Regarding comparable selection for ITES services, the tribunal restored R Systems International to AO/TPO for fresh examination despite different accounting year, as matching period data was available. However, it directed exclusion of Infosys BPO Ltd due to specialized services commanding premium pricing versus assessee's low-end back office support, and MPS Ltd for providing different services like content creation and platform development. The tribunal also restored working capital and risk adjustment issues to AO/TPO. For section 14A disallowance, it rejected Rule 8D application, accepting assessee's alternative computation of Rs. 5,52,490 based on proportionate expense allocation between business and exempt income. Case-Laws Income Tax Thu, 18 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462485