Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Delayed recovery of associated enterprise receivables was held not to justify a working capital transfer pricing adjustment where the branch was debt-free, had no borrowings or interest claim, and its working capital needs were funded by head office, so no opportunity cost or borrowed-funds assumption was shown. The Tribunal therefore found no basis to interfere with deletion of the adjustment. Interest under section 234D was treated as consequential, and that ground was accepted on the assessee's concession.
Delayed recovery of associated enterprise receivables was held not to justify a working capital transfer pricing adjustment where the branch was debt-free, had no borrowings or interest claim, and its working capital needs were funded by head office, so no opportunity cost or borrowed-funds assumption was shown. The Tribunal therefore found no basis to interfere with deletion of the adjustment. Interest under section 234D was treated as consequential, and that ground was accepted on the assessee's concession.
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