Transfer pricing appeals partly allowed; specified comparables excluded or remitted, some included; s.234A interest disallowed, recompute tax and refund

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....ITAT allowed the taxpayer's transfer pricing challenges in part. Two specified comparables were excluded from the final set on the basis of identical FAR findings in prior co-ordinate bench decisions; one specified reseller comparable was held comparable and included. Several other comparables engaged in trading were remitted to the AO/TPO for fresh verification against prescribed filters and segmental reporting. The Tribunal excluded multiple education-service comparables for functional dissimilarity, remitted others for verification of segmental revenues, and included one education comparable. Several software-development comparables were excluded, while a specific IT services comparable qualified for inclusion; additional IT comparables .........