https://www.taxtmi.com/caselaws?id=769065 ITAT Mumbai rejected three companies (Cybage Software Pvt.Ltd, Nihilent Ltd., and Techwava Infotech Pvt.Ltd) as comparables due to functional dissimilarity. Regarding notional interest on outstanding receivables from associated enterprises, the TPO's computation using LIBOR plus 400 basis points was challenged. The tribunal held that proper transfer pricing study was required considering credit periods of comparables and applicable LIBOR rates. The matter was remitted to AO/TPO with directions to apply LIBOR plus 300 basis points for receivables outside working capital adjustment, following RBI guidelines and precedent from Cotton Naturals case. en-us Fri, 28 Feb 2025 00:00:00 +0530 Wed, 16 Apr 2025 15:22:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769065 ITAT Mumbai rejected three companies (Cybage Software Pvt.Ltd, Nihilent Ltd., and Techwava Infotech Pvt.Ltd) as comparables due to functional dissimilarity. Regarding notional interest on outstanding receivables from associated enterprises, the TPO's computation using LIBOR plus 400 basis points was challenged. The tribunal held that proper transfer pricing study was required considering credit periods of comparables and applicable LIBOR rates. The matter was remitted to AO/TPO with directions to apply LIBOR plus 300 basis points for receivables outside working capital adjustment, following RBI guidelines and precedent from Cotton Naturals case. Case-Laws Income Tax Fri, 28 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769065