https://www.taxtmi.com/caselaws?id=468270 Section 10A computation is discussed as including training income with a direct nexus to the export software business, while telecommunication expenses attributable to export activity must be treated consistently in the turnover computation. The transfer pricing analysis states that the tested party should ordinarily be the least complex entity for which reliable comparable data exists; on the facts, selection of foreign associated enterprises as tested party was found unsustainable, and the 5% tolerance range under section 92C(2) was applied. Notional interest on delayed receivables required invoice-wise re-examination after the normal credit period, while interest on foreign currency loans to associated enterprises was benchmarked on a LIBOR-based CUP. Capital contribution to a wholly owned foreign subsidiary was not re-characterised as a loan, and the customization fee adjustment was deleted. en-us Thu, 19 Feb 2026 00:00:00 +0530 Fri, 24 Apr 2026 19:49:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468270 Section 10A computation is discussed as including training income with a direct nexus to the export software business, while telecommunication expenses attributable to export activity must be treated consistently in the turnover computation. The transfer pricing analysis states that the tested party should ordinarily be the least complex entity for which reliable comparable data exists; on the facts, selection of foreign associated enterprises as tested party was found unsustainable, and the 5% tolerance range under section 92C(2) was applied. Notional interest on delayed receivables required invoice-wise re-examination after the normal credit period, while interest on foreign currency loans to associated enterprises was benchmarked on a LIBOR-based CUP. Capital contribution to a wholly owned foreign subsidiary was not re-characterised as a loan, and the customization fee adjustment was deleted. Case-Laws Income Tax Thu, 19 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468270