https://www.taxtmi.com/caselaws?id=467773 Comparables lacking functional similarity in a captive software development services segment cannot be used for arm's length price benchmarking, so the five disputed comparables were excluded and the transfer pricing computation was recomputed. An adjustment on outstanding receivables based on SBI term deposit rates was unsustainable where prior bench rulings required LIBOR-based benchmarking for such international transactions, so the receivables adjustment was deleted. The depreciation claim linked to foreign exchange loss treated as capital expenditure required fresh examination, so that issue was remanded for reconsideration in accordance with law. en-us Tue, 17 Aug 2021 00:00:00 +0530 Thu, 02 Apr 2026 15:26:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467773 Comparables lacking functional similarity in a captive software development services segment cannot be used for arm's length price benchmarking, so the five disputed comparables were excluded and the transfer pricing computation was recomputed. An adjustment on outstanding receivables based on SBI term deposit rates was unsustainable where prior bench rulings required LIBOR-based benchmarking for such international transactions, so the receivables adjustment was deleted. The depreciation claim linked to foreign exchange loss treated as capital expenditure required fresh examination, so that issue was remanded for reconsideration in accordance with law. Case-Laws Income Tax Tue, 17 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467773