https://www.taxtmi.com/caselaws?id=447627 ITAT MUMBAI - AT held that the TPO erred in ignoring revenue while assessing warranty-service margins; the assessee's accounting is accepted and margin is computed on full revenue of INR 19,16,24,516 (35.71%), so the transfer-pricing addition of INR 13,99,71,558 is deleted. For software-development services, the TPO's exclusion of several comparables was set aside and specific companies were directed to be included; TPO must verify segmental results for one group company. On notional interest for overdue receivables the issue is remanded: TPO to compute interest invoice-wise beyond the applicable grace period after receiving particulars; grace period to follow AE agreements or market practice; applicable rate: LIBOR + 200 bps. en-us Wed, 27 Dec 2023 00:00:00 +0530 Fri, 29 Aug 2025 14:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447627 ITAT MUMBAI - AT held that the TPO erred in ignoring revenue while assessing warranty-service margins; the assessee's accounting is accepted and margin is computed on full revenue of INR 19,16,24,516 (35.71%), so the transfer-pricing addition of INR 13,99,71,558 is deleted. For software-development services, the TPO's exclusion of several comparables was set aside and specific companies were directed to be included; TPO must verify segmental results for one group company. On notional interest for overdue receivables the issue is remanded: TPO to compute interest invoice-wise beyond the applicable grace period after receiving particulars; grace period to follow AE agreements or market practice; applicable rate: LIBOR + 200 bps. Case-Laws Income Tax Wed, 27 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447627