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Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjustment.
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Retrospective insertion of section 144C(13A) places the final assessment order within the prescribed limitation period, rejecting the time-bar challenge. Cost-to-cost recovery of withholding tax paid for associated enterprises' restricted stock units is non-operating because it is unrelated to the assessee's ITeS services, and must be excluded from its operating margin. Voice-based call-centre, general IT/BPO, technical-helpdesk and intellectual-property consultancy providers are functionally incomparable with diversified technical ITeS services, while knowledge-processing services may remain comparable. Delayed associated-enterprise receivables, though international transactions, require combined benchmarking with the underlying ITeS transaction; once a working-capital adjustment is granted under TNMM, separate notional interest is unwarranted.
Retrospective insertion of section 144C(13A) places the final assessment order within the prescribed limitation period, rejecting the time-bar challenge. Cost-to-cost recovery of withholding tax paid for associated enterprises' restricted stock units is non-operating because it is unrelated to the assessee's ITeS services, and must be excluded from its operating margin. Voice-based call-centre, general IT/BPO, technical-helpdesk and intellectual-property consultancy providers are functionally incomparable with diversified technical ITeS services, while knowledge-processing services may remain comparable. Delayed associated-enterprise receivables, though international transactions, require combined benchmarking with the underlying ITeS transaction; once a working-capital adjustment is granted under TNMM, separate notional interest is unwarranted.
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