https://www.taxtmi.com/caselaws?id=402433 Transfer pricing comparables for a captive software development and ITeS provider must be functionally similar, so companies engaged in product development, mixed operations, significant intangibles, or lacking reliable segmental data were excluded from benchmarking. For ITeS, brand-driven and KPO-oriented entities were also rejected as comparables. Working capital adjustment was denied for want of proper substantiation. Outstanding receivables were treated as an international transaction, but the interest benchmark was directed to be determined on a LIBOR-linked basis rather than SBI PLR. en-us Fri, 18 Dec 2020 00:00:00 +0530 Fri, 01 Jan 2021 10:21:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402433 Transfer pricing comparables for a captive software development and ITeS provider must be functionally similar, so companies engaged in product development, mixed operations, significant intangibles, or lacking reliable segmental data were excluded from benchmarking. For ITeS, brand-driven and KPO-oriented entities were also rejected as comparables. Working capital adjustment was denied for want of proper substantiation. Outstanding receivables were treated as an international transaction, but the interest benchmark was directed to be determined on a LIBOR-linked basis rather than SBI PLR. Case-Laws Income Tax Fri, 18 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402433