https://www.taxtmi.com/caselaws?id=314562 ITAT Delhi held that four companies were not suitable comparables for transfer pricing analysis of software development services: Larsen Tourbro Infotech Ltd. (due to amalgamation and significant intangibles), Tata Elxsi Ltd. (functionally dissimilar with internally generated intangibles), Infobeans Technologies Ltd. (rejected for captive service providers), and Cybercom Datamatics Information Solutions Ltd. After excluding these comparables, assessee's margin fell within arm's length range, requiring no adjustment. Additionally, ITAT deleted transfer pricing adjustment on notional interest for delayed receivables from associated enterprises, following precedent that mere receivables don't constitute international transactions under section 92B explanation, particularly for debt-free companies. Appeal allowed. en-us Wed, 23 Nov 2022 00:00:00 +0530 Mon, 24 Jun 2024 16:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314562 ITAT Delhi held that four companies were not suitable comparables for transfer pricing analysis of software development services: Larsen Tourbro Infotech Ltd. (due to amalgamation and significant intangibles), Tata Elxsi Ltd. (functionally dissimilar with internally generated intangibles), Infobeans Technologies Ltd. (rejected for captive service providers), and Cybercom Datamatics Information Solutions Ltd. After excluding these comparables, assessee's margin fell within arm's length range, requiring no adjustment. Additionally, ITAT deleted transfer pricing adjustment on notional interest for delayed receivables from associated enterprises, following precedent that mere receivables don't constitute international transactions under section 92B explanation, particularly for debt-free companies. Appeal allowed. Case-Laws Income Tax Wed, 23 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314562