https://www.taxtmi.com/caselaws?id=787577 DRP directions deleting disallowances for exempt-income-related adjustments, TDS-related uplinking/transmission charges, software capitalisation, ESOP expense and exclusion of specified comparables are upheld because no exempt income arose, the payments were not taxable to the nonresident recipient, the software had revenue character, ESOP liability met mercantile deductibility and the excluded firms were functionally dissimilar; inclusion of APITCO as a comparable is set aside for lack of product/functional similarity. The alleged corporate guarantee is remitted to the assessing officer/TPO for fresh determination whether it constitutes an international transaction. en-us Fri, 06 Mar 2026 00:00:00 +0530 Sat, 07 Mar 2026 13:07:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787577 DRP directions deleting disallowances for exempt-income-related adjustments, TDS-related uplinking/transmission charges, software capitalisation, ESOP expense and exclusion of specified comparables are upheld because no exempt income arose, the payments were not taxable to the nonresident recipient, the software had revenue character, ESOP liability met mercantile deductibility and the excluded firms were functionally dissimilar; inclusion of APITCO as a comparable is set aside for lack of product/functional similarity. The alleged corporate guarantee is remitted to the assessing officer/TPO for fresh determination whether it constitutes an international transaction. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787577