Transfer pricing comparability was applied on functional profile and reliable data: Datamatics Business Solutions was excluded because it performed high-end KPO functions unlike a routine captive BPO, while R Systems International could be included if quarterly public results enable a reliable margin computation. Micro Land was included on consistency grounds despite not appearing in the search matrix. Working capital differences under TNMM required fresh verification, and interest on delayed foreign-currency receivables was to be recomputed using LIBOR plus 200 basis points for the actual delay period. The section 43B disallowance was restored for factual verification, and interest under sections 234A and 234C was held unsustainable or required recomputation in the assessee's favour.
Transfer pricing comparability was applied on functional profile and reliable data: Datamatics Business Solutions was excluded because it performed high-end KPO functions unlike a routine captive BPO, while R Systems International could be included if quarterly public results enable a reliable margin computation. Micro Land was included on consistency grounds despite not appearing in the search matrix. Working capital differences under TNMM required fresh verification, and interest on delayed foreign-currency receivables was to be recomputed using LIBOR plus 200 basis points for the actual delay period. The section 43B disallowance was restored for factual verification, and interest under sections 234A and 234C was held unsustainable or required recomputation in the assessee's favour.
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