https://www.taxtmi.com/caselaws?id=307444 Functional comparability under TNMM requires reliable record-based analysis of software service comparables, and where the material does not conclusively establish comparability, the matter may be remanded for fresh examination; challenges not properly raised below may be rejected. Delayed realisation of trade receivables from associated enterprises may also require separate transfer pricing benchmarking as an international transaction, particularly where no adequate benchmark or transfer pricing study is shown for the receivable period. Loan-based or LIBOR-based benchmarks are not automatically interchangeable with receivables. The receivables adjustment was upheld in principle, but the interest rate applied was reduced from 8% to 6%. en-us Tue, 07 Jun 2022 00:00:00 +0530 Sat, 27 Sep 2025 10:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307444 Functional comparability under TNMM requires reliable record-based analysis of software service comparables, and where the material does not conclusively establish comparability, the matter may be remanded for fresh examination; challenges not properly raised below may be rejected. Delayed realisation of trade receivables from associated enterprises may also require separate transfer pricing benchmarking as an international transaction, particularly where no adequate benchmark or transfer pricing study is shown for the receivable period. Loan-based or LIBOR-based benchmarks are not automatically interchangeable with receivables. The receivables adjustment was upheld in principle, but the interest rate applied was reduced from 8% to 6%. Case-Laws Income Tax Tue, 07 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307444