https://www.taxtmi.com/caselaws?id=196161 Transfer pricing comparability for a captive service provider depends on functional profile, scale, ownership of intangibles, risk assumption and business model, so companies engaged in product development, integrated hardware-software solutions, heavy outsourcing or otherwise materially different operations were excluded as comparables. Working capital adjustment had to be computed on the India branch's standalone segmental balances, with payables and receivables differences neutralised on the correct data set, and the matter was remitted for fresh computation. Software transferred by an Indian branch to its foreign head office, when developed for that head office and not sold to third parties, could qualify as export for section 10A purposes, so denial of the deduction was set aside for reconsideration. en-us Fri, 23 Dec 2016 00:00:00 +0530 Tue, 21 Nov 2017 08:40:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=196161 Transfer pricing comparability for a captive service provider depends on functional profile, scale, ownership of intangibles, risk assumption and business model, so companies engaged in product development, integrated hardware-software solutions, heavy outsourcing or otherwise materially different operations were excluded as comparables. Working capital adjustment had to be computed on the India branch's standalone segmental balances, with payables and receivables differences neutralised on the correct data set, and the matter was remitted for fresh computation. Software transferred by an Indian branch to its foreign head office, when developed for that head office and not sold to third parties, could qualify as export for section 10A purposes, so denial of the deduction was set aside for reconsideration. Case-Laws Income Tax Fri, 23 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=196161