https://www.taxtmi.com/highlights?id=99152 In transfer pricing for captive software development services, high turnover comparables were excluded because a wide turnover gap distorts economies of scale, brand value, market positioning and risk profile; entities with turnover above 200 crore were therefore removed and the arm's length price recomputed. Companies with diversified or specialised functions outside captive software development were also excluded as functionally dissimilar, leading to fresh computation of the profit level indicator and ALP. For delayed foreign currency trade receivables, SBI PLR was rejected as an inappropriate domestic benchmark, and LIBOR plus 200 basis points was applied after allowing the agreed or standard credit period for recomputation of the adjustment. en-us Sat, 25 Apr 2026 08:51:42 +0530 Sat, 25 Apr 2026 08:51:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99152 In transfer pricing for captive software development services, high turnover comparables were excluded because a wide turnover gap distorts economies of scale, brand value, market positioning and risk profile; entities with turnover above 200 crore were therefore removed and the arm's length price recomputed. Companies with diversified or specialised functions outside captive software development were also excluded as functionally dissimilar, leading to fresh computation of the profit level indicator and ALP. For delayed foreign currency trade receivables, SBI PLR was rejected as an inappropriate domestic benchmark, and LIBOR plus 200 basis points was applied after allowing the agreed or standard credit period for recomputation of the adjustment. Highlights Income Tax Sat, 25 Apr 2026 08:51:42 +0530 https://www.taxtmi.com/highlights?id=99152