Transfer-pricing analysis for software development and...

Transfer-pricing analysis for software development and maintenance support services addresses the limits of applying an APA margin outside its covered assessment years. Foreign exchange fluctuation directly linked to those services is treated as operating income. A working-capital adjustment must be considered where supporting workings are furnished, subject to verification, and the resulting comparable margin must be tested against the statutory tolerance range; no adjustment remains if it falls within that range. Comparable-selection issues become academic on that basis. The note also addresses short credit for tax deducted at source, requiring factual verification and fresh adjudication.