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...
The High Court held that the Bright Line Test could not be adopted for transfer pricing because it is not provided under the Income-tax Act, 1961 or the Rules and is alien to the statutory scheme; the proposed question was rejected. It also declined to entertain the royalty adjustment questions, noting that the need for any transfer pricing adjustment, the computation method, and the arm's length price had already been decided in the assessee's own cases, with no contrary Supreme Court ruling shown. The exclusion of Febulka Advertising Pvt. Ltd. as a comparable was treated as a factual finding based on its different business and incomplete public data, beyond interference under section 260A. The appeal was dismissed.
The High Court held that the Bright Line Test could not be adopted for transfer pricing because it is not provided under the Income-tax Act, 1961 or the Rules and is alien to the statutory scheme; the proposed question was rejected. It also declined to entertain the royalty adjustment questions, noting that the need for any transfer pricing adjustment, the computation method, and the arm's length price had already been decided in the assessee's own cases, with no contrary Supreme Court ruling shown. The exclusion of Febulka Advertising Pvt. Ltd. as a comparable was treated as a factual finding based on its different business and incomplete public data, beyond interference under section 260A. The appeal was dismissed.
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