Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Assessment against deceased sole proprietor requires proceedings against the legal representative, rendering prior assessment and appellate orders inv...
Residential waste collection classification under SAC 999423 defeats composite-supply exemption where facilitating goods are not transferred to the lo...
Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Transfer pricing comparables for software development services...
Turnover filters and receivables benchmarking reshape software-services transfer pricing: high-turnover comparables excluded and interest recomputed at LIBOR plus 2%
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Transfer pricing comparables for software development services should exclude companies with substantially higher turnover where their inclusion would distort the margins of a smaller captive service provider. Applying the accepted turnover range of Rs. 1 crore to Rs. 200 crores, the Tribunal directed exclusion of companies exceeding the upper limit and recomputation of the arm's length price. Foreign-currency receivables from associated-enterprise transactions were treated as international transactions for transfer pricing purposes. However, the interest adjustment was not accepted at the rate previously applied; it was directed to be recomputed using LIBOR plus 2%. The appeal was allowed for statistical purposes.
Transfer pricing comparables for software development services should exclude companies with substantially higher turnover where their inclusion would distort the margins of a smaller captive service provider. Applying the accepted turnover range of Rs. 1 crore to Rs. 200 crores, the Tribunal directed exclusion of companies exceeding the upper limit and recomputation of the arm's length price. Foreign-currency receivables from associated-enterprise transactions were treated as international transactions for transfer pricing purposes. However, the interest adjustment was not accepted at the rate previously applied; it was directed to be recomputed using LIBOR plus 2%. The appeal was allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
