Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Financial irregularities found by SEBI rendered Acropetal Technologies Ltd.'s accounts and margins unreliable, so its exclusion from the comparables set was upheld for transfer pricing purposes. The Tribunal noted that diversion of funds to non-business use can materially distort operating margins and followed prior co-ordinate bench decisions excluding the same company. For intra-group support services, it accepted that a later APA margin could have persuasive value for a non-APA year where the transactions were identical, the FAR profile was unchanged, and documentary evidence supported receipt of services. The transfer pricing adjustment on support services was therefore deleted.
Financial irregularities found by SEBI rendered Acropetal Technologies Ltd.'s accounts and margins unreliable, so its exclusion from the comparables set was upheld for transfer pricing purposes. The Tribunal noted that diversion of funds to non-business use can materially distort operating margins and followed prior co-ordinate bench decisions excluding the same company. For intra-group support services, it accepted that a later APA margin could have persuasive value for a non-APA year where the transactions were identical, the FAR profile was unchanged, and documentary evidence supported receipt of services. The transfer pricing adjustment on support services was therefore deleted.
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