https://www.taxtmi.com/caselaws?id=467561 Transfer pricing comparability must account for material turnover differences in the software development segment, and very high-turnover companies may be excluded when compared with a smaller service provider. Related party transaction filters and functional comparability also require verification, and selected comparables may be remitted for reconsideration where prior bench rulings or factual examination are incomplete. Differences in working capital materially affect margins, so working capital adjustment should be allowed when justified. Outstanding receivables constitute an international transaction that must be benchmarked under the Act and Rules, and any revised interest basis must be tested after giving the assessee a fair hearing. en-us Mon, 13 Jun 2022 00:00:00 +0530 Tue, 24 Mar 2026 14:24:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467561 Transfer pricing comparability must account for material turnover differences in the software development segment, and very high-turnover companies may be excluded when compared with a smaller service provider. Related party transaction filters and functional comparability also require verification, and selected comparables may be remitted for reconsideration where prior bench rulings or factual examination are incomplete. Differences in working capital materially affect margins, so working capital adjustment should be allowed when justified. Outstanding receivables constitute an international transaction that must be benchmarked under the Act and Rules, and any revised interest basis must be tested after giving the assessee a fair hearing. Case-Laws Income Tax Mon, 13 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467561