https://www.taxtmi.com/caselaws?id=789654 In transfer pricing analysis, Chartered Accountant-certified segmental financial statements for software development cannot be discarded merely because they are unaudited or show margin variation; the allocation method and expense apportionment must first be tested for reliability, and the data may require verification before any arm's length price redetermination. Separate adjustment for overdue receivables must also be assessed within the overall transfer pricing framework, including working capital adjustment. If working capital adjustment is allowed, the separate receivables addition may not survive; if not, foreign-currency invoices should be benchmarked with an appropriate foreign-currency rate rather than a domestic lending rate. en-us Wed, 08 Apr 2026 00:00:00 +0530 Sat, 11 Apr 2026 08:53:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789654 In transfer pricing analysis, Chartered Accountant-certified segmental financial statements for software development cannot be discarded merely because they are unaudited or show margin variation; the allocation method and expense apportionment must first be tested for reliability, and the data may require verification before any arm's length price redetermination. Separate adjustment for overdue receivables must also be assessed within the overall transfer pricing framework, including working capital adjustment. If working capital adjustment is allowed, the separate receivables addition may not survive; if not, foreign-currency invoices should be benchmarked with an appropriate foreign-currency rate rather than a domestic lending rate. Case-Laws Income Tax Wed, 08 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789654