Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
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 
TaxTMI 
of 4817 
Join Channel 
