https://www.taxtmi.com/caselaws?id=796302 Transfer-pricing comparability in the software development segment requires fresh examination of Ishir Infotech, Sasken Communication Technologies, Tata Elxsi and Akshay Software. The notes identify outstanding verification of employee-cost and section 133(6) information, merger and acquisition events, functional comparability of embedded product-design activities, and onsite-offshore margin data used for the onsite-revenue filter. They state that the comparability exercise should be remitted to the Transfer Pricing Officer after giving the assessee a reasonable opportunity. Penalty proceedings linked to the transfer-pricing adjustment also require fresh determination because the underlying quantum issues have been remitted. en-us Thu, 11 Jun 2026 00:00:00 +0530 Tue, 04 Aug 2026 08:39:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796302 Transfer-pricing comparability in the software development segment requires fresh examination of Ishir Infotech, Sasken Communication Technologies, Tata Elxsi and Akshay Software. The notes identify outstanding verification of employee-cost and section 133(6) information, merger and acquisition events, functional comparability of embedded product-design activities, and onsite-offshore margin data used for the onsite-revenue filter. They state that the comparability exercise should be remitted to the Transfer Pricing Officer after giving the assessee a reasonable opportunity. Penalty proceedings linked to the transfer-pricing adjustment also require fresh determination because the underlying quantum issues have been remitted. Case-Laws Income Tax Thu, 11 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796302