Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
ITAT upheld characterization of outstanding dues beyond agreed credit period as separate international transaction of providing finance, requiring separate benchmarking. Interest adjustment limited to financial year under consideration. RBI COVID-19 relaxations not applicable to relevant period. No recharacterization of transaction by TPO. Commercial expediency for delayed receivables not established. Netting of receivables/payables permitted if demonstrated. Lack of show cause notice not fatal. Working capital adjustment to be considered for removing interest adjustment. MAT book profit computation remitted for rectification. Directed to grant tax credits after verification.
ITAT upheld characterization of outstanding dues beyond agreed credit period as separate international transaction of providing finance, requiring separate benchmarking. Interest adjustment limited to financial year under consideration. RBI COVID-19 relaxations not applicable to relevant period. No recharacterization of transaction by TPO. Commercial expediency for delayed receivables not established. Netting of receivables/payables permitted if demonstrated. Lack of show cause notice not fatal. Working capital adjustment to be considered for removing interest adjustment. MAT book profit computation remitted for rectification. Directed to grant tax credits after verification.
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