https://www.taxtmi.com/caselaws?id=468313 Transfer pricing benchmarking of software development services requires comparables that are functionally similar and have reliable segmental data. Software product companies lacking adequate segmental information for software development services should be excluded from the comparable set, requiring recomputation of the transfer pricing adjustment. Foreign exchange gain arising from the international transaction forms part of operating income and must be included in operating profit when calculating the operating profit to operating cost margin. The profit level indicator must therefore reflect both the revised comparable set and foreign exchange gain as operating income. 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 of software development services requires comparables that are functionally similar and have reliable segmental data. Software product companies lacking adequate segmental information for software development services should be excluded from the comparable set, requiring recomputation of the transfer pricing adjustment. Foreign exchange gain arising from the international transaction forms part of operating income and must be included in operating profit when calculating the operating profit to operating cost margin. The profit level indicator must therefore reflect both the revised comparable set and foreign exchange gain as operating income. Case-Laws Income Tax Thu, 06 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468313