https://www.taxtmi.com/caselaws?id=290250 Transfer pricing under TNMM requires comparables to be functionally similar and free from material distortions. Larsen & Toubro Infotech Ltd. was rejected because it operated across multiple segments and had restructuring and acquisition events that made margins unreliable; Tata Elxsi Ltd. was excluded because its segment covered product design, graphics animation and gaming; Cybercom Datamatics Information Solutions Ltd. was excluded for mixed software services and product activities. The resulting adjustment on software development services was deleted. On receivables, no notional interest adjustment was permitted because the receivables were incidental to the underlying sales or service transactions, the assessee was debt free, and no separate interest cost or independent loan transaction was shown. en-us Mon, 29 Jun 2020 00:00:00 +0530 Wed, 16 Sep 2020 11:09:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290250 Transfer pricing under TNMM requires comparables to be functionally similar and free from material distortions. Larsen & Toubro Infotech Ltd. was rejected because it operated across multiple segments and had restructuring and acquisition events that made margins unreliable; Tata Elxsi Ltd. was excluded because its segment covered product design, graphics animation and gaming; Cybercom Datamatics Information Solutions Ltd. was excluded for mixed software services and product activities. The resulting adjustment on software development services was deleted. On receivables, no notional interest adjustment was permitted because the receivables were incidental to the underlying sales or service transactions, the assessee was debt free, and no separate interest cost or independent loan transaction was shown. Case-Laws Income Tax Mon, 29 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290250