Transfer pricing tolerance rules govern software development and...

Transfer pricing tolerance rules govern software development and online advertisement support services where the tested party's margins or transaction prices fall within the prescribed range. Foreign exchange gains or losses linked to export invoices may be operating items for IT-enabled services, subject to verification and corresponding treatment in comparable-company margins. Income from sale of SEIS scrips is non-operating because it arises from an incentive scheme rather than service exports, requiring parity adjustments for comparables. Comparable selection requires final search criteria and detailed FAR analysis: companies with negligible IT-enabled services activity may be excluded, while additional or previously selected comparables may be reconsidered. Comparable-margin computations require verification and correct application.