Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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Turnover is a relevant comparability criterion in transfer pricing because scale affects profitability, risk profile, asset base, bargaining power and economies of scale; the Tribunal therefore upheld use of an upper turnover filter and rejected the Revenue's challenge to exclusion of high-turnover comparables. For inclusion of I2T2 India Limited and Cigniti Technologies Limited, the Tribunal held that a comparable cannot be adopted merely by relying on an earlier order without verifying contemporaneous financials, functional profile, applicable filters and segmental data for the year in question; that issue was remanded to the Assessing Officer/TPO for fresh examination after hearing the assessee.
Turnover is a relevant comparability criterion in transfer pricing because scale affects profitability, risk profile, asset base, bargaining power and economies of scale; the Tribunal therefore upheld use of an upper turnover filter and rejected the Revenue's challenge to exclusion of high-turnover comparables. For inclusion of I2T2 India Limited and Cigniti Technologies Limited, the Tribunal held that a comparable cannot be adopted merely by relying on an earlier order without verifying contemporaneous financials, functional profile, applicable filters and segmental data for the year in question; that issue was remanded to the Assessing Officer/TPO for fresh examination after hearing the assessee.
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