https://www.taxtmi.com/caselaws?id=793222 Revenue delay in filing the transfer pricing appeal was condoned on a liberal approach, supported by affidavit evidence of administrative pendency and absence of mala fides. In the software development segment, exclusions of CG-VAK Software & Exports Ltd., Larsen & Toubro Infotech Ltd., Tech Mahindra Ltd. and Persistent Systems Ltd. were upheld on functional, risk, intangibles, segmental data and product-led business differences, while Spry Resources India Pvt. Ltd. was directed to be included despite high receivables. In ITeS, Hartron Communications Ltd., Capgemini Business Services (India) Pvt. Ltd. and Infosys BPO Ltd. were excluded. Negative working capital adjustment was held impermissible for a captive cost-plus service provider, and the comparability of Sasken Communication Technologies Ltd. and Informed Technologies India Ltd. was remanded for fresh examination. en-us Tue, 26 May 2026 00:00:00 +0530 Thu, 11 Jun 2026 08:33:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793222 Revenue delay in filing the transfer pricing appeal was condoned on a liberal approach, supported by affidavit evidence of administrative pendency and absence of mala fides. In the software development segment, exclusions of CG-VAK Software & Exports Ltd., Larsen & Toubro Infotech Ltd., Tech Mahindra Ltd. and Persistent Systems Ltd. were upheld on functional, risk, intangibles, segmental data and product-led business differences, while Spry Resources India Pvt. Ltd. was directed to be included despite high receivables. In ITeS, Hartron Communications Ltd., Capgemini Business Services (India) Pvt. Ltd. and Infosys BPO Ltd. were excluded. Negative working capital adjustment was held impermissible for a captive cost-plus service provider, and the comparability of Sasken Communication Technologies Ltd. and Informed Technologies India Ltd. was remanded for fresh examination. Case-Laws Income Tax Tue, 26 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793222