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Income Tax - Highlights / Catch Notes

Home Highlights April 2025 Year 2025 This

ITAT directs selective inclusion and exclusion of comparables ...


Tribunal Mandates Precise Comparable Selection Methodology for IT Service Segment Assessments with Functional and Risk-Based Criteria

April 12, 2025

Case Laws     Income Tax     AT

ITAT directs selective inclusion and exclusion of comparables across multiple service segments. Key determinations include excluding Innovana Thinklabs Ltd. and K7 Computing Pvt Ltd due to limited risk profile, remanding certain comparables for detailed verification, and accepting specific companies like Sonata Information Technology Ltd and Akshay Software Technologies Ltd. The tribunal mandated working capital adjustments and proportionate margin computations, emphasizing functional similarity and segmental compatibility as primary criteria for comparable selection. The ruling instructs the Assessing Officer to comprehensively re-evaluate comparable companies using precise filtering parameters across software development, IT-enabled services, and training segments.

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