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The Tribunal addressed various issues related to transfer pricing adjustments, including the selection of comparables, interest on trade receivables, and set-off of losses. Regarding comparables, the Tribunal upheld the inclusion of E-Infochips Bangalore Ltd. and Mindtree, rejecting the assessee's objections. However, it excluded Persistent Systems Ltd. due to the absence of inventory related to software products. Concerning interest on trade receivables, the Tribunal followed the DRP's decision to restrict interest to LIBOR plus 250 basis points, despite contrary Tribunal precedents, as the Revenue did not appeal the DRP's order. The Tribunal dismissed the assessee's ground regarding set-off of losses between units, citing the lack of objection before the DRP and the restriction u/s 92C(4) proviso. The order provides clarity on the Tribunal's approach to various transfer pricing issues.
The Tribunal addressed various issues related to transfer pricing adjustments, including the selection of comparables, interest on trade receivables, and set-off of losses. Regarding comparables, the Tribunal upheld the inclusion of E-Infochips Bangalore Ltd. and Mindtree, rejecting the assessee's objections. However, it excluded Persistent Systems Ltd. due to the absence of inventory related to software products. Concerning interest on trade receivables, the Tribunal followed the DRP's decision to restrict interest to LIBOR plus 250 basis points, despite contrary Tribunal precedents, as the Revenue did not appeal the DRP's order. The Tribunal dismissed the assessee's ground regarding set-off of losses between units, citing the lack of objection before the DRP and the restriction u/s 92C(4) proviso. The order provides clarity on the Tribunal's approach to various transfer pricing issues.
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