https://www.taxtmi.com/caselaws?id=463834 ITAT held that several software-segment comparables were properly excluded due to excessive onsite revenue and differing business models; two other comparables were remitted to the AO/TPO/DRP for fresh consideration given differing factual years. In the ITES segment, a comparable was excluded as functionally dissimilar. Interest on outstanding receivables was held to be an international transaction; the assessee's non-compliance with DRP directions supported rejection of its plea, and the TPO was directed to compute interest using LIBOR-6 months plus 300 basis points. One ground was allowed for statistical purposes. en-us Tue, 28 Feb 2023 00:00:00 +0530 Wed, 17 Sep 2025 13:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463834 ITAT held that several software-segment comparables were properly excluded due to excessive onsite revenue and differing business models; two other comparables were remitted to the AO/TPO/DRP for fresh consideration given differing factual years. In the ITES segment, a comparable was excluded as functionally dissimilar. Interest on outstanding receivables was held to be an international transaction; the assessee's non-compliance with DRP directions supported rejection of its plea, and the TPO was directed to compute interest using LIBOR-6 months plus 300 basis points. One ground was allowed for statistical purposes. Case-Laws Income Tax Tue, 28 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463834