ITAT allowed assessee's appeal regarding transfer pricing...

ITAT allowed assessee's appeal regarding transfer pricing adjustments on software development services and ECB interest payments. For SDS benchmarking, ITAT held TPO/DRP erred by including five high-turnover comparables (Infosys, Wipro, Larsen & Turbo Infotech, Mindtree, Tata Elxsi) without applying turnover filter. Matter remanded to TPO for fresh benchmarking using ten-times turnover filter range. Regarding INR-denominated ECB interest, ITAT ruled TPO incorrectly rejected assessee's SBI-PLR benchmarking approach in favor of Masala Bond rates. Following precedents including Adama India and Invesco India, ITAT held INR-denominated loans should be benchmarked against domestic Indian rupee lending rates, not external rates carrying different lender risks. Assessee's 10.45% interest rate against SBI-PLR 13.75% deemed arm's length. TP adjustment vacated. AO directed to verify advance tax credit claim per 26AS disclosure.

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