https://www.taxtmi.com/caselaws?id=783060 ITAT partly allowed the revenue's appeal and partly allowed the assessee's cross-objections in a transfer pricing dispute. For the EDS segment, inclusion of CADSYS (India) Pvt. Ltd. was allowed, but the assessee's related grounds were treated as academic as its margin remained within arm's length. For the software development services segment, the Tribunal directed exclusion of Infosys Ltd., Three Sixty Logica Testing Services Pvt. Ltd., Indianic Infotech Ltd., Nihilent Ltd. and Cybage Software Pvt. Ltd. from the set of comparables on functional/turnover and data grounds. The issue of Evoke Technologies Ltd. was remitted to the AO/TPO for fresh consideration. The AO/TPO was directed to recompute ALP accordingly, with remaining grounds held academic. en-us Fri, 28 Nov 2025 00:00:00 +0530 Tue, 09 Dec 2025 08:41:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783060 ITAT partly allowed the revenue's appeal and partly allowed the assessee's cross-objections in a transfer pricing dispute. For the EDS segment, inclusion of CADSYS (India) Pvt. Ltd. was allowed, but the assessee's related grounds were treated as academic as its margin remained within arm's length. For the software development services segment, the Tribunal directed exclusion of Infosys Ltd., Three Sixty Logica Testing Services Pvt. Ltd., Indianic Infotech Ltd., Nihilent Ltd. and Cybage Software Pvt. Ltd. from the set of comparables on functional/turnover and data grounds. The issue of Evoke Technologies Ltd. was remitted to the AO/TPO for fresh consideration. The AO/TPO was directed to recompute ALP accordingly, with remaining grounds held academic. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783060