Comparable Excluded Due to Functional Dissimilarity in Software Development Transfer Pricing

ACIT Vs Bahwan Cybertek Private Limited (ITAT Chennai)

The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) dealt with cross appeals filed by the Revenue and the assessee, along with a cross-objection by the assessee, arising out of the assessment for Assessment Year (AY) 2017–18. The appeals challenged the order of the Commissioner of Income Tax (Appeals) [CIT(A)] relating to transfer pricing adjustments, treatment of certain expenditures, and the grant of foreign tax credit.

At the outset, the Tribun

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