https://www.taxtmi.com/caselaws?id=468313 Transfer pricing benchmarking for a software development service provider should be confined to functionally similar companies with reliable segmental data, so software product companies lacking usable segmentation are not suitable comparables. On that basis, Larsen & Toubro Infotech Ltd. and Persistent Systems Ltd. were excluded from the comparable set. The article also notes that foreign exchange gain arising from the international transaction forms part of operating income for computing the operating profit to operating cost margin, and the profit level indicator must be recomputed accordingly. en-us Thu, 06 Feb 2020 00:00:00 +0530 Tue, 28 Apr 2026 15:59:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468313 Transfer pricing benchmarking for a software development service provider should be confined to functionally similar companies with reliable segmental data, so software product companies lacking usable segmentation are not suitable comparables. On that basis, Larsen & Toubro Infotech Ltd. and Persistent Systems Ltd. were excluded from the comparable set. The article also notes that foreign exchange gain arising from the international transaction forms part of operating income for computing the operating profit to operating cost margin, and the profit level indicator must be recomputed accordingly. Case-Laws Income Tax Thu, 06 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468313