https://www.taxtmi.com/caselaws?id=310450 The ITAT Bangalore ruled on transfer pricing adjustments involving USD-denominated trade receivables and ITES segment comparables. For interest on receivables, the tribunal held LIBOR plus appropriate markup as the proper benchmark for international USD transactions rather than Indian interest rates. The TPO was directed to determine proper markup over LIBOR and compute interest only on receivables outstanding beyond arm's length credit periods. Regarding comparable selection for ITES segment, several companies were excluded due to high turnover filters - TCS E-Serve and Infosys BPO were deemed non-comparable due to significantly higher turnover than the assessee. The matter was remanded for examination of segment-wise data reliability and employee cost filters for remaining comparables, with directions to allow negative working capital adjustment for captive service providers. en-us Wed, 10 Aug 2022 00:00:00 +0530 Wed, 06 Mar 2024 17:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310450 The ITAT Bangalore ruled on transfer pricing adjustments involving USD-denominated trade receivables and ITES segment comparables. For interest on receivables, the tribunal held LIBOR plus appropriate markup as the proper benchmark for international USD transactions rather than Indian interest rates. The TPO was directed to determine proper markup over LIBOR and compute interest only on receivables outstanding beyond arm's length credit periods. Regarding comparable selection for ITES segment, several companies were excluded due to high turnover filters - TCS E-Serve and Infosys BPO were deemed non-comparable due to significantly higher turnover than the assessee. The matter was remanded for examination of segment-wise data reliability and employee cost filters for remaining comparables, with directions to allow negative working capital adjustment for captive service providers. Case-Laws Income Tax Wed, 10 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310450