https://www.taxtmi.com/caselaws?id=304017 Functional comparability in transfer pricing must be tested against a captive, low-risk software development service provider, so companies with diversified operations, product development, significant intangibles, extraordinary events, absent segmental data, or failed filters were excluded from the comparables set. Working capital adjustment is to be computed on actual differences and allowed on verifiable data. Interest on external commercial borrowings must be benchmarked under the applicable foreign currency loan framework. Recharacterisation of marketing support services as a commission agency model requires proper examination of contractual functions and evidence, and may be remanded for fresh verification. Depreciation was allowed on free of cost assets once capitalised and brought into computation, while seconded employee costs, bonding and debonding charges, and tax credits or deductions were sent back for factual verification. en-us Thu, 30 Jun 2022 00:00:00 +0530 Wed, 13 Mar 2024 12:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304017 Functional comparability in transfer pricing must be tested against a captive, low-risk software development service provider, so companies with diversified operations, product development, significant intangibles, extraordinary events, absent segmental data, or failed filters were excluded from the comparables set. Working capital adjustment is to be computed on actual differences and allowed on verifiable data. Interest on external commercial borrowings must be benchmarked under the applicable foreign currency loan framework. Recharacterisation of marketing support services as a commission agency model requires proper examination of contractual functions and evidence, and may be remanded for fresh verification. Depreciation was allowed on free of cost assets once capitalised and brought into computation, while seconded employee costs, bonding and debonding charges, and tax credits or deductions were sent back for factual verification. Case-Laws Income Tax Thu, 30 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304017