Logitech Engineering & Design India P. Ltd vs DCIT
Whether the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) correctly selected comparables for benchmarking the assessee's international transactions of software development services and market support services under the Transactional Net Margin Method (TNMM) --- Held No, the Tribunal directed exclusions and inclusions based on functional comparability, turnover filters, related party transaction filters, and availability of segmental information.
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