https://www.taxtmi.com/caselaws?id=469145 Service tax refund linked to a captive service provider's cost-plus billing was treated as operating income because it directly reversed an operating expense, with any interest component excluded. The related party transactions filter was accepted on an aggregate basis and the 15% sales threshold applied. Comparable selection in software development and marketing support was controlled by functional similarity, segmental data, onsite operations, extraordinary events, brand strength, related party exposure, and diversified activities; unsuitable comparables were excluded and some matters remitted. Trade receivables were treated as a separate international transaction outside working capital adjustment, with interest to be recomputed after a 60-day credit period using LIBOR plus 300 basis points. ESOP expenditure was held to be revenue employee cost and allowable. en-us Fri, 15 Dec 2023 00:00:00 +0530 Fri, 05 Jun 2026 18:19:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469145 Service tax refund linked to a captive service provider's cost-plus billing was treated as operating income because it directly reversed an operating expense, with any interest component excluded. The related party transactions filter was accepted on an aggregate basis and the 15% sales threshold applied. Comparable selection in software development and marketing support was controlled by functional similarity, segmental data, onsite operations, extraordinary events, brand strength, related party exposure, and diversified activities; unsuitable comparables were excluded and some matters remitted. Trade receivables were treated as a separate international transaction outside working capital adjustment, with interest to be recomputed after a 60-day credit period using LIBOR plus 300 basis points. ESOP expenditure was held to be revenue employee cost and allowable. Case-Laws Income Tax Fri, 15 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469145