https://www.taxtmi.com/caselaws?id=791010 Transfer pricing comparability was refined by excluding Datamatics Business Solutions for its high-end KPO profile and lack of reliable segmental data, while R Systems International was to be tested on quarterly results despite a different financial year if reliable reconstruction was possible. Micro Land was included on consistency because no material functional change was shown. Working capital adjustment was remanded for fresh scientific computation, and notional interest on trade receivables was to be recomputed using LIBOR plus 200 basis points for the actual delay period. The processing-stage disallowance was restored for verification under section 43B, and interest under section 234A was deleted while section 234C interest was to be recomputed on returned income. en-us Tue, 24 Feb 2026 00:00:00 +0530 Sat, 06 Jun 2026 10:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791010 Transfer pricing comparability was refined by excluding Datamatics Business Solutions for its high-end KPO profile and lack of reliable segmental data, while R Systems International was to be tested on quarterly results despite a different financial year if reliable reconstruction was possible. Micro Land was included on consistency because no material functional change was shown. Working capital adjustment was remanded for fresh scientific computation, and notional interest on trade receivables was to be recomputed using LIBOR plus 200 basis points for the actual delay period. The processing-stage disallowance was restored for verification under section 43B, and interest under section 234A was deleted while section 234C interest was to be recomputed on returned income. Case-Laws Income Tax Tue, 24 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791010