https://www.taxtmi.com/caselaws?id=785711 A diversified IT and consultancy company without segmental software-development data was not a valid comparable for benchmarking a routine software development service provider, so its exclusion was upheld. Corporate guarantees to an associated enterprise were treated as international transactions, and 0.5% was accepted as the arm's length commission because bank guarantee rates were not directly comparable. Expenditure on hardware and software consumables was held to be revenue in nature as it did not create an enduring asset. Foreign tax credit on dividend income from Oman was allowed because the treaty permitted credit for tax paid or deemed paid, and no taxpayer-specific certificate was required. en-us Fri, 21 Nov 2025 00:00:00 +0530 Thu, 29 Jan 2026 14:09:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785711 A diversified IT and consultancy company without segmental software-development data was not a valid comparable for benchmarking a routine software development service provider, so its exclusion was upheld. Corporate guarantees to an associated enterprise were treated as international transactions, and 0.5% was accepted as the arm's length commission because bank guarantee rates were not directly comparable. Expenditure on hardware and software consumables was held to be revenue in nature as it did not create an enduring asset. Foreign tax credit on dividend income from Oman was allowed because the treaty permitted credit for tax paid or deemed paid, and no taxpayer-specific certificate was required. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785711