https://www.taxtmi.com/caselaws?id=773510 ITAT Hyderabad allowed the assessee's appeal regarding transfer pricing adjustments on software development services and ECB interest payments. The tribunal directed exclusion of five high-turnover comparables (including major IT companies) from benchmarking analysis and ordered fresh comparable search with turnover filter of ten times on both ends. For INR-denominated ECB interest payments, the tribunal held that domestic Indian rupee lending rates (SBI-PLR) were appropriate benchmarks rather than Masala Bond rates, as currency risk wasn't borne by borrower. The TP adjustment on interest payments was vacated, and AO was directed to verify advance tax credit claims. en-us Mon, 02 Jun 2025 00:00:00 +0530 Tue, 24 Jun 2025 08:25:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773510 ITAT Hyderabad allowed the assessee's appeal regarding transfer pricing adjustments on software development services and ECB interest payments. The tribunal directed exclusion of five high-turnover comparables (including major IT companies) from benchmarking analysis and ordered fresh comparable search with turnover filter of ten times on both ends. For INR-denominated ECB interest payments, the tribunal held that domestic Indian rupee lending rates (SBI-PLR) were appropriate benchmarks rather than Masala Bond rates, as currency risk wasn't borne by borrower. The TP adjustment on interest payments was vacated, and AO was directed to verify advance tax credit claims. Case-Laws Income Tax Mon, 02 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773510