Income Tax Officer vs Sabre Travel Technologies Pvt. Ltd.

Whether the Transfer Pricing Officer (TPO) correctly determined the Arm's Length Price (ALP) for software development services by selecting appropriate comparable companies and computing working capital adjustment? --- Held: Partly in favor of the assessee; the matter is remanded for fresh consideration of working capital adjustment. Whether the deduction under Section 10A should be computed by excluding telecommunication expenses, insurance charges, and foreign exchange loss from both export turnover and total turnover? --- Held: Yes, following jurisdictional High Court and Supreme Court precedents. Whether lease rentals paid for fit-outs should be treated as revenue expenditure? --- Held: The issue is remanded to the Assessing Officer for fresh adjudication.