Tribunal Excludes Non-Comparable Companies in Transfer Pricing Case and Allows Section 10A Deductions for Multiple Units

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....ITAT directed exclusion of several comparables for transfer pricing adjustments in software development services (Infosys Ltd, Persistent Systems Ltd, Tata Elexi Ltd, Bodhtree Consulting Ltd) and ITeS (Eclerx Services Ltd, Cosmic Global Ltd, Accentia Technologies Ltd, Infosys BPO Ltd) due to functional differences and lack of segmental information. The Tribunal allowed deductions under s.10A for UB Plaza Unit, Titanium STPI Unit, and the unit acquired from Reuters India, following previous favorable decisions. The issue of depreciation on goodwill was restored to AO for de novo adjudication. ITAT upheld DRP's direction to exclude communication and travel expenses from both export and total turnover while computing s.10A deduction, following HCL Technologies Ltd precedent, and affirmed deletion of software disallowance under s.40(a)(ia) per Tally Solutions ruling.....