https://www.taxtmi.com/caselaws?id=468404 Transfer pricing in certification and ITES segments was revisited on functional comparability, segmental data and related party filters. Foreign exchange gain or loss on revenue items directly linked to the service transaction was to be treated as operating, and the adjustment confined to international transactions with the associated enterprise. In the ITES segment, functionally different comparables were excluded, other comparables were included, and working capital adjustment was allowed on actuals. The challenge to the change in revenue recognition method was rejected, though consequential relief was preserved to avoid double taxation. TDS credit and interest under sections 234A and 234B were directed to be verified and allowed in accordance with law. en-us Mon, 22 Nov 2021 00:00:00 +0530 Tue, 05 May 2026 12:01:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468404 Transfer pricing in certification and ITES segments was revisited on functional comparability, segmental data and related party filters. Foreign exchange gain or loss on revenue items directly linked to the service transaction was to be treated as operating, and the adjustment confined to international transactions with the associated enterprise. In the ITES segment, functionally different comparables were excluded, other comparables were included, and working capital adjustment was allowed on actuals. The challenge to the change in revenue recognition method was rejected, though consequential relief was preserved to avoid double taxation. TDS credit and interest under sections 234A and 234B were directed to be verified and allowed in accordance with law. Case-Laws Income Tax Mon, 22 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468404