https://www.taxtmi.com/caselaws?id=439749 Transfer pricing review for software development and services directs multiple remittals to the assessing officer/transfer pricing officer for fresh consideration and verification of comparability, functional analysis and margin computations, with specific directions to allow specified comparables if they pass FAR analysis. The RPT ratio must be computed on an aggregate basis (RPT income plus RPT expenses by sales). Fixed asset write-offs are to be treated as non-operating per earlier directions. Provision for doubtful debts is to be treated as operating only if attributable to the current year; otherwise non-operating. Cash PLI adoption is confirmed. Notional interest on overdue receivables is an international transaction to be computed at 6-month LIBOR plus 300 bps. Goodwill depreciation arising on amalgamation requires verification to avoid double benefits. en-us Mon, 26 Jun 2023 00:00:00 +0530 Wed, 28 Jan 2026 16:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439749 Transfer pricing review for software development and services directs multiple remittals to the assessing officer/transfer pricing officer for fresh consideration and verification of comparability, functional analysis and margin computations, with specific directions to allow specified comparables if they pass FAR analysis. The RPT ratio must be computed on an aggregate basis (RPT income plus RPT expenses by sales). Fixed asset write-offs are to be treated as non-operating per earlier directions. Provision for doubtful debts is to be treated as operating only if attributable to the current year; otherwise non-operating. Cash PLI adoption is confirmed. Notional interest on overdue receivables is an international transaction to be computed at 6-month LIBOR plus 300 bps. Goodwill depreciation arising on amalgamation requires verification to avoid double benefits. Case-Laws Income Tax Mon, 26 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439749