https://www.taxtmi.com/caselaws?id=303961 High-turnover companies may be excluded as comparables when benchmarking a smaller software development service provider under the transactional net margin method, and R S Software (India) Limited may be retained with only the relevant year margin considered. Separate transfer pricing adjustment for notional interest on delayed receivables is generally not warranted where a working capital adjustment already captures the receivables effect. Payments for software licences must be tested under the copyright versus copyrighted article distinction to determine whether the amount is royalty and whether withholding tax disallowance applies. en-us Thu, 12 May 2022 00:00:00 +0530 Sun, 28 Aug 2022 12:56:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=303961 High-turnover companies may be excluded as comparables when benchmarking a smaller software development service provider under the transactional net margin method, and R S Software (India) Limited may be retained with only the relevant year margin considered. Separate transfer pricing adjustment for notional interest on delayed receivables is generally not warranted where a working capital adjustment already captures the receivables effect. Payments for software licences must be tested under the copyright versus copyrighted article distinction to determine whether the amount is royalty and whether withholding tax disallowance applies. Case-Laws Income Tax Thu, 12 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=303961