Tribunal Eliminates Transfer Pricing Adjustments After Excluding Non-Comparable Companies Under Section 92C

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....The ITAT ruled in favor of the assessee on multiple transfer pricing issues. The Tribunal excluded comparables Tata Elexi and Sasken Technologies, bringing the appellant's margin (9.44%) within acceptable range (11.66% +/-3%), eliminating TP adjustment. Similarly, ADTL and TCG were excluded as comparables for CRDS services. The ITAT deleted TP adjustments for intra-group services and advertisement/marketing expenses, finding the latter not to be international transactions. Additional favorable rulings included: no SS14A disallowance where no exempt income was earned; deletion of duplicative SS41(1) addition for trading liability cessation; allowance of lease rental expenses for assets on financial lease; and confirmation that SS80G deduction for CSR contributions remains available despite Explanation 2 to SS37(1).....