https://www.taxtmi.com/caselaws?id=304160 The Tribunal partly allowed the Assessee's appeal, directing the TPO/AO to recompute the Arm's Length Price (ALP) for Software Development Services (SWD) by excluding companies with high turnover. Additionally, the Tribunal instructed the TPO/AO to verify invoice-wise details for delayed receivables before determining any notional interest, emphasizing that if no delay occurred beyond the agreed credit period, no international transaction should be considered, and no notional interest should be attributed. The TPO/AO was directed to provide the Assessee with an opportunity to be heard before making a decision. en-us Wed, 25 May 2022 00:00:00 +0530 Sat, 10 Sep 2022 07:01:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304160 The Tribunal partly allowed the Assessee's appeal, directing the TPO/AO to recompute the Arm's Length Price (ALP) for Software Development Services (SWD) by excluding companies with high turnover. Additionally, the Tribunal instructed the TPO/AO to verify invoice-wise details for delayed receivables before determining any notional interest, emphasizing that if no delay occurred beyond the agreed credit period, no international transaction should be considered, and no notional interest should be attributed. The TPO/AO was directed to provide the Assessee with an opportunity to be heard before making a decision. Case-Laws Income Tax Wed, 25 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304160