https://www.taxtmi.com/caselaws?id=210912 ITAT held that arms-length pricing for international software development transactions must use only operating costs allocable to the associated-enterprise segment (excluding bad debts/reimbursements); no foreign-exchange adjustment was warranted as the assessee's margin fell within the ALP range. Interest on foreign-currency loans should be benchmarked to LIBOR; matter remitted to AO to verify applicable average LIBOR (partly allowed). Corporate guarantee to bank for subsidiary loans is not an international transaction, so no TP adjustment. Telecommunication and implementation expenses excluded from both export turnover and total turnover for deduction under s.10A. s.14A disallowance remitted to AO for recomputation. en-us Fri, 09 Sep 2011 00:00:00 +0530 Wed, 20 Aug 2025 17:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210912 ITAT held that arms-length pricing for international software development transactions must use only operating costs allocable to the associated-enterprise segment (excluding bad debts/reimbursements); no foreign-exchange adjustment was warranted as the assessee's margin fell within the ALP range. Interest on foreign-currency loans should be benchmarked to LIBOR; matter remitted to AO to verify applicable average LIBOR (partly allowed). Corporate guarantee to bank for subsidiary loans is not an international transaction, so no TP adjustment. Telecommunication and implementation expenses excluded from both export turnover and total turnover for deduction under s.10A. s.14A disallowance remitted to AO for recomputation. Case-Laws Income Tax Fri, 09 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210912