https://www.taxtmi.com/caselaws?id=468554 Transfer pricing analysis for an engineering support assessee turned on functional characterisation, comparability and receivable-interest benchmarking. The re-characterisation of structural detailing and back-end support from ITeS to KPO was rejected because the FAR analysis did not support a high-end knowledge-based profile, and the transfer pricing study was accepted. Operating margin was to be recomputed by excluding COVID-period salary cost, finance cost on long-term borrowings and foreign exchange loss as non-operating or extraordinary items. L&T Technology Services Ltd. and XS CAD India Pvt. Ltd. were excluded as comparables, while additional comparables were remitted for verification. Interest on receivables was upheld on a 60-day credit period, with the rate to be benchmarked at LIBOR plus 200 basis points. en-us Fri, 31 Oct 2025 00:00:00 +0530 Thu, 18 Jun 2026 16:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468554 Transfer pricing analysis for an engineering support assessee turned on functional characterisation, comparability and receivable-interest benchmarking. The re-characterisation of structural detailing and back-end support from ITeS to KPO was rejected because the FAR analysis did not support a high-end knowledge-based profile, and the transfer pricing study was accepted. Operating margin was to be recomputed by excluding COVID-period salary cost, finance cost on long-term borrowings and foreign exchange loss as non-operating or extraordinary items. L&T Technology Services Ltd. and XS CAD India Pvt. Ltd. were excluded as comparables, while additional comparables were remitted for verification. Interest on receivables was upheld on a 60-day credit period, with the rate to be benchmarked at LIBOR plus 200 basis points. Case-Laws Income Tax Fri, 31 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468554