https://www.taxtmi.com/caselaws?id=436494 Classification of the taxpayer's activity for transfer pricing benchmarking was decisive: the service segment is placement and HR consultancy, not ITES, and the TP adjustment based on ITES comparables is set aside with direction for fresh analysis treating the taxpayer as placement/HR services provider. Application of TNMM at entity level was rejected; the ALP must be determined using margin analysis of the AE segment alone and AO/TPO directed to accept segmental margins. Interest on delayed receivables must be computed on net receivables after netting payables and using LIBOR plus credit risk spread; matter remitted for recomputation. Disallowance for delayed employee PF/ESI remittance was upheld against the taxpayer. en-us Tue, 10 Jan 2023 00:00:00 +0530 Sat, 24 Jan 2026 11:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436494 Classification of the taxpayer's activity for transfer pricing benchmarking was decisive: the service segment is placement and HR consultancy, not ITES, and the TP adjustment based on ITES comparables is set aside with direction for fresh analysis treating the taxpayer as placement/HR services provider. Application of TNMM at entity level was rejected; the ALP must be determined using margin analysis of the AE segment alone and AO/TPO directed to accept segmental margins. Interest on delayed receivables must be computed on net receivables after netting payables and using LIBOR plus credit risk spread; matter remitted for recomputation. Disallowance for delayed employee PF/ESI remittance was upheld against the taxpayer. Case-Laws Income Tax Tue, 10 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436494