Transfer Pricing Dispute: Tribunal Modifies Comparable Companies List and Clarifies Investment-Related Tax Assessments

ITAT adjudicated transfer pricing and tax assessment matters involving a software services company. The tribunal directed inclusion of Sasken Communication Technologies Ltd in comparable companies list, while excluding Wipro, Tata Elxsi, Infosys, and Larsen & Toubro Infotech due to segmental reporting disparities. On Rule 14A disallowance, the tribunal held that investments from non-interest bearing funds do not warrant interest expenditure disallowance. The tribunal restored the disallowance computation to the Assessing Officer, noting only dividend-yielding investments should be considered. Regarding section 143(1) adjustments, the tribunal advised the assessee to seek remedy through separate proceedings, finding the current forum inappropriate for addressing such grievances. .....

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