https://www.taxtmi.com/caselaws?id=468506 Transfer pricing adjustment was confined to controlled international transactions, and several comparables were excluded or remitted because they were functionally dissimilar, affected by extraordinary events, or lacked proper segmental data; risk adjustment became academic after the revised comparables set placed the assessee within arm's length range. Negative working capital adjustment was disallowed because the assessee operated in a captive, risk-mitigated model. Deduction under section 10A for the ORSC unit was not finally denied and was restored for verification of eligibility and unused deduction period. Software licence fee was treated as capital expenditure, but depreciation was allowed at 60% on computer software. Refund credit was also directed to be verified and granted in the consequential computation. en-us Fri, 06 Jan 2017 00:00:00 +0530 Mon, 11 May 2026 11:09:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468506 Transfer pricing adjustment was confined to controlled international transactions, and several comparables were excluded or remitted because they were functionally dissimilar, affected by extraordinary events, or lacked proper segmental data; risk adjustment became academic after the revised comparables set placed the assessee within arm's length range. Negative working capital adjustment was disallowed because the assessee operated in a captive, risk-mitigated model. Deduction under section 10A for the ORSC unit was not finally denied and was restored for verification of eligibility and unused deduction period. Software licence fee was treated as capital expenditure, but depreciation was allowed at 60% on computer software. Refund credit was also directed to be verified and granted in the consequential computation. Case-Laws Income Tax Fri, 06 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468506