https://www.taxtmi.com/caselaws?id=466675 Tribunal directed reworking of arm's length price determinations for certification services, IT/management fees, royalty and ITeS by AO/TPO, requiring proper functional comparability filters, contemporaneous data, permitted economic adjustments and full working capital adjustment; certain comparables were excluded and others remanded for verification, and combined benchmarking for royalty must be examined before separate benchmarking. Additional evidence for IT/management fees was admitted and remitted for fresh consideration. Corporate tax issues were partly allowed and partly remitted: change in revenue recognition was rejected but consequential relief granted where deferred revenue was taxed; TDS credit, export-related deduction and set-off/deprediation and interest claims were remanded or directed as applicable. en-us Thu, 24 Feb 2022 00:00:00 +0530 Mon, 16 Feb 2026 20:10:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466675 Tribunal directed reworking of arm's length price determinations for certification services, IT/management fees, royalty and ITeS by AO/TPO, requiring proper functional comparability filters, contemporaneous data, permitted economic adjustments and full working capital adjustment; certain comparables were excluded and others remanded for verification, and combined benchmarking for royalty must be examined before separate benchmarking. Additional evidence for IT/management fees was admitted and remitted for fresh consideration. Corporate tax issues were partly allowed and partly remitted: change in revenue recognition was rejected but consequential relief granted where deferred revenue was taxed; TDS credit, export-related deduction and set-off/deprediation and interest claims were remanded or directed as applicable. Case-Laws Income Tax Thu, 24 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466675