https://www.taxtmi.com/caselaws?id=289377 Transfer pricing for software development and ITeS required operating revenue to be confined to the relevant year, so prior period income was excluded. Comparability turned on functional profile, segmental data, scale, brand intangibles, extraordinary events and related party exposure, leading to exclusion of several functionally dissimilar comparables, while the working capital adjustment was upheld. An alternate deduction claim under section 10A could be examined on appeal despite a section 10B disallowance when the material facts were already on record, and foreign exchange fluctuation linked to receivables and payables was treated as operating for PLI computation, with the adjustment to be applied consistently. en-us Fri, 20 Dec 2019 00:00:00 +0530 Thu, 14 Nov 2024 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289377 Transfer pricing for software development and ITeS required operating revenue to be confined to the relevant year, so prior period income was excluded. Comparability turned on functional profile, segmental data, scale, brand intangibles, extraordinary events and related party exposure, leading to exclusion of several functionally dissimilar comparables, while the working capital adjustment was upheld. An alternate deduction claim under section 10A could be examined on appeal despite a section 10B disallowance when the material facts were already on record, and foreign exchange fluctuation linked to receivables and payables was treated as operating for PLI computation, with the adjustment to be applied consistently. Case-Laws Income Tax Fri, 20 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289377