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    <title>2023 (11) TMI 47 - DELHI HIGH COURT</title>
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    <description>The Delhi HC upheld the Tribunal&#039;s decision rejecting three companies as comparables for transfer pricing analysis. The Court found that Infobeans Technologies was properly excluded due to functional dissimilarity with the assessee, Cybercom was rejected for providing different technical services, and Infosys BPO was excluded as a risk-bearing entity with diversified activities compared to the assessee&#039;s limited BPO operations. Regarding interest on receivables adjustment, the HC agreed with the Tribunal&#039;s decision to remand the matter to the Assessing Officer for verification of the assessee&#039;s 90-day credit period claim. The Court ruled that once working capital adjustment is made, no further adjustment for interest on receivables is required, as this would distort the transaction analysis.</description>
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      <link>https://www.taxtmi.com/caselaws?id=445156</link>
      <description>The Delhi HC upheld the Tribunal&#039;s decision rejecting three companies as comparables for transfer pricing analysis. The Court found that Infobeans Technologies was properly excluded due to functional dissimilarity with the assessee, Cybercom was rejected for providing different technical services, and Infosys BPO was excluded as a risk-bearing entity with diversified activities compared to the assessee&#039;s limited BPO operations. Regarding interest on receivables adjustment, the HC agreed with the Tribunal&#039;s decision to remand the matter to the Assessing Officer for verification of the assessee&#039;s 90-day credit period claim. The Court ruled that once working capital adjustment is made, no further adjustment for interest on receivables is required, as this would distort the transaction analysis.</description>
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