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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.
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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