https://www.taxtmi.com/caselaws?id=788717 A captive software development service provider should not be benchmarked against an IP-driven product development entity where the latter lacks reliable segmental data separating software services from entrepreneurial and licensing activities. On the comparability analysis, Persistent Systems Ltd. was treated as functionally different and excluded, while Akshay Software Technologies Ltd., Cigniti Technologies Ltd. and Evoke Technologies Pvt. Ltd. were accepted as comparables because their revenues and functions were aligned with software services. Foreign tax credit was stated to depend on verification of foreign tax payment, corresponding Indian taxation and the prescribed declaration, so the claim required examination by the Assessing Officer. Working capital adjustment was also to be allowed after necessary verification. en-us Thu, 18 Dec 2025 00:00:00 +0530 Fri, 27 Mar 2026 08:52:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788717 A captive software development service provider should not be benchmarked against an IP-driven product development entity where the latter lacks reliable segmental data separating software services from entrepreneurial and licensing activities. On the comparability analysis, Persistent Systems Ltd. was treated as functionally different and excluded, while Akshay Software Technologies Ltd., Cigniti Technologies Ltd. and Evoke Technologies Pvt. Ltd. were accepted as comparables because their revenues and functions were aligned with software services. Foreign tax credit was stated to depend on verification of foreign tax payment, corresponding Indian taxation and the prescribed declaration, so the claim required examination by the Assessing Officer. Working capital adjustment was also to be allowed after necessary verification. Case-Laws Income Tax Thu, 18 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788717