https://www.taxtmi.com/caselaws?id=790456 Transfer-pricing comparability for captive software development services must exclude entities with materially higher turnover where scale, brand value, market position, and risk profile distort comparability, and it must also exclude functionally dissimilar businesses engaged in diversified or specialised non-comparable activities. For foreign currency trade receivables from associated enterprises, domestic lending rates such as SBI PLR are not appropriate; the benchmark should reflect a foreign-currency rate, with LIBOR plus basis points applied after the normal credit period. The resulting adjustment is to be recomputed on that basis. en-us Thu, 01 Jan 2026 00:00:00 +0530 Sat, 25 Apr 2026 08:51:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790456 Transfer-pricing comparability for captive software development services must exclude entities with materially higher turnover where scale, brand value, market position, and risk profile distort comparability, and it must also exclude functionally dissimilar businesses engaged in diversified or specialised non-comparable activities. For foreign currency trade receivables from associated enterprises, domestic lending rates such as SBI PLR are not appropriate; the benchmark should reflect a foreign-currency rate, with LIBOR plus basis points applied after the normal credit period. The resulting adjustment is to be recomputed on that basis. Case-Laws Income Tax Thu, 01 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790456