In a transfer pricing dispute involving software development...
Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit verification directed.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
In a transfer pricing dispute involving software development services, the ITAT held that the persistent loss filter applied only where a company incurred losses in all three relevant years, so DCIS Dot Com Solutions India Pvt. Ltd. and Rheal Software Pvt. Ltd. were to be included as comparables. It further held that Mind Tree Limited and Nihilent Limited were functionally dissimilar, lacked usable segmental information for software development services, and were to be excluded as comparables. Foreign exchange gain arising from realization of service receivables was held to be operating income for PLI computation. The claim for risk adjustment was restored for fresh consideration, and credit for self-assessment tax and TCS was directed to be granted after verification.
In a transfer pricing dispute involving software development services, the ITAT held that the persistent loss filter applied only where a company incurred losses in all three relevant years, so DCIS Dot Com Solutions India Pvt. Ltd. and Rheal Software Pvt. Ltd. were to be included as comparables. It further held that Mind Tree Limited and Nihilent Limited were functionally dissimilar, lacked usable segmental information for software development services, and were to be excluded as comparables. Foreign exchange gain arising from realization of service receivables was held to be operating income for PLI computation. The claim for risk adjustment was restored for fresh consideration, and credit for self-assessment tax and TCS was directed to be granted after verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
