PURPLETALK INDIA PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-9(1), HYDERABAD

TDS default.", "held": "The Tribunal addressed several grounds of appeal. It dismissed general grounds, rejected the assessee's argument for using internal TNMM, and upheld the rejection of the assessee's TP study due to inappropriate filters and data. The Tribunal also directed the exclusion of specific companies from the comparable list and instructed the AO/TPO to give full effect

GAINSIGHT SOFTWARE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERSABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

92D of the Act read with rule 10D of the Income Tax Rules, 1962. 5. On the facts and circumstances of the case and in law, the Ld. TPO / Ld. AO / Ld. DRP erred in: a. rejecting certain filters adopted in the transfer pricing study; and b. application of certain filters which are not relevant to the Appellant. Comparability