https://www.taxtmi.com/caselaws?id=401659 Transfer pricing analysis in captive software development requires exclusion of comparables that are functionally dissimilar, lack reliable segmental data, or derive mixed product-service revenues, while margin calculations based on unallocable expenditure may need verification. In software distribution, resale of products purchased from an associated enterprise points to the resale price method, and the adjustment is limited to the value of the international transaction. Outstanding receivables may be treated as a separate international transaction, but no separate interest adjustment is warranted where working capital adjustment already covers year-end balances; delayed collections beyond the agreed credit period may still be benchmarked separately, including on a LIBOR plus spread basis for foreign-currency receivables. en-us Thu, 26 Nov 2020 00:00:00 +0530 Mon, 14 Dec 2020 09:54:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401659 Transfer pricing analysis in captive software development requires exclusion of comparables that are functionally dissimilar, lack reliable segmental data, or derive mixed product-service revenues, while margin calculations based on unallocable expenditure may need verification. In software distribution, resale of products purchased from an associated enterprise points to the resale price method, and the adjustment is limited to the value of the international transaction. Outstanding receivables may be treated as a separate international transaction, but no separate interest adjustment is warranted where working capital adjustment already covers year-end balances; delayed collections beyond the agreed credit period may still be benchmarked separately, including on a LIBOR plus spread basis for foreign-currency receivables. Case-Laws Income Tax Thu, 26 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401659