https://www.taxtmi.com/caselaws?id=759125 Functional comparability on FAR analysis supported retention of E-Infochips Bangalore Limited, Kals Information Systems Limited, Persistent Systems Limited and Mindtree Limited in the transfer pricing set. Delayed trade receivables were also subjected to a notional interest adjustment, but only at the DRP's restricted benchmark of LIBOR plus 250 basis points, which was not disturbed in the assessee's appeal. The article further notes that the Hyderabad unit loss set-off against Pune STPI unit profit, and the related section 10A relief claim, were not entertained because the issue had not been raised before the DRP and was treated as procedurally and substantively unsustainable at that stage. en-us Tue, 23 Jul 2024 00:00:00 +0530 Mon, 23 Sep 2024 18:16:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759125 Functional comparability on FAR analysis supported retention of E-Infochips Bangalore Limited, Kals Information Systems Limited, Persistent Systems Limited and Mindtree Limited in the transfer pricing set. Delayed trade receivables were also subjected to a notional interest adjustment, but only at the DRP's restricted benchmark of LIBOR plus 250 basis points, which was not disturbed in the assessee's appeal. The article further notes that the Hyderabad unit loss set-off against Pune STPI unit profit, and the related section 10A relief claim, were not entertained because the issue had not been raised before the DRP and was treated as procedurally and substantively unsustainable at that stage. Case-Laws Income Tax Tue, 23 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759125