https://www.taxtmi.com/caselaws?id=467809 A captive software development service provider on a cost-plus, low-risk model cannot be benchmarked against companies with materially different functions, product orientation, entrepreneurial risk, or unreliable segmental data; accordingly, Infosys Limited, Persistent Systems Limited, Tata Elxsi Limited, e-Infochips Private Limited, Wipro Limited, Nihilent Technologies Limited and Infobeans Technologies Limited were excluded as comparables. Outstanding foreign-currency receivables from associated enterprises were treated as an international transaction requiring transfer pricing benchmarking, and the appropriate benchmark was held to be LIBOR-linked rather than a domestic rupee rate, with a 60-day credit period considered reasonable. The receivables adjustment was revised on that basis, granting partial relief. en-us Wed, 16 Jul 2025 00:00:00 +0530 Sat, 04 Apr 2026 08:51:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467809 A captive software development service provider on a cost-plus, low-risk model cannot be benchmarked against companies with materially different functions, product orientation, entrepreneurial risk, or unreliable segmental data; accordingly, Infosys Limited, Persistent Systems Limited, Tata Elxsi Limited, e-Infochips Private Limited, Wipro Limited, Nihilent Technologies Limited and Infobeans Technologies Limited were excluded as comparables. Outstanding foreign-currency receivables from associated enterprises were treated as an international transaction requiring transfer pricing benchmarking, and the appropriate benchmark was held to be LIBOR-linked rather than a domestic rupee rate, with a 60-day credit period considered reasonable. The receivables adjustment was revised on that basis, granting partial relief. Case-Laws Income Tax Wed, 16 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467809