Software-development comparability turned on material differences in turnover, scalability, brand value, assets employed and functional, asset and risk profile. Mindtree Ltd., LTI Mindtree Ltd. and Tata Consultancy Services, having substantially greater scale and brand value than a captive service provider, were excluded from the comparable set. Interest on delayed receivables arising from foreign-currency invoices required benchmarking using LIBOR plus an appropriate mark-up, or another appropriate rate, rather than SBI rates. The resulting treatment required fresh benchmarking of interest on those receivables.
Software-development comparability turned on material differences in turnover, scalability, brand value, assets employed and functional, asset and risk profile. Mindtree Ltd., LTI Mindtree Ltd. and Tata Consultancy Services, having substantially greater scale and brand value than a captive service provider, were excluded from the comparable set. Interest on delayed receivables arising from foreign-currency invoices required benchmarking using LIBOR plus an appropriate mark-up, or another appropriate rate, rather than SBI rates. The resulting treatment required fresh benchmarking of interest on those receivables.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
