Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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SEIS-related income had been consistently treated as non-operating, so its reversal was also required to be treated similarly to preserve comparability in TNMM margin analysis. Foreign exchange fluctuation arising from realisation of export receivables was held to be intrinsically linked to publishing support services and therefore operating in nature. On that basis, the assessee's margin fell within the arm's length range and the transfer pricing adjustment on publishing support services was deleted. The Tribunal also held that working capital adjustment is a recognised comparability adjustment under TNMM and cannot be denied merely because daily data is unavailable; reasonable approximations from opening and closing balances may be used. The AO/TPO was directed to grant the adjustment, and no further TP adjustment survived on this issue.
SEIS-related income had been consistently treated as non-operating, so its reversal was also required to be treated similarly to preserve comparability in TNMM margin analysis. Foreign exchange fluctuation arising from realisation of export receivables was held to be intrinsically linked to publishing support services and therefore operating in nature. On that basis, the assessee's margin fell within the arm's length range and the transfer pricing adjustment on publishing support services was deleted. The Tribunal also held that working capital adjustment is a recognised comparability adjustment under TNMM and cannot be denied merely because daily data is unavailable; reasonable approximations from opening and closing balances may be used. The AO/TPO was directed to grant the adjustment, and no further TP adjustment survived on this issue.
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