https://www.taxtmi.com/caselaws?id=469928 A captive software development service provider could not be benchmarked against Wipro Technology Services Ltd. or Infosys Ltd. because both were functionally dissimilar, with different risk profiles, brand intangibles, products and scale; working capital adjustment was also allowable where the record showed material differences between the tested party and comparables. A mark-up on out-of-pocket expenses recovered from associated enterprises was unsustainable because arm's length price was not determined under a prescribed transfer pricing method. Telecommunication and related expenses were to be excluded from export turnover for section 10A computation, no disallowance under section 14A could be made in the absence of exempt income, and government grant receipts were treated as capital subsidy and capital in nature. en-us Thu, 23 Feb 2023 00:00:00 +0530 Thu, 09 Jul 2026 15:08:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469928 A captive software development service provider could not be benchmarked against Wipro Technology Services Ltd. or Infosys Ltd. because both were functionally dissimilar, with different risk profiles, brand intangibles, products and scale; working capital adjustment was also allowable where the record showed material differences between the tested party and comparables. A mark-up on out-of-pocket expenses recovered from associated enterprises was unsustainable because arm's length price was not determined under a prescribed transfer pricing method. Telecommunication and related expenses were to be excluded from export turnover for section 10A computation, no disallowance under section 14A could be made in the absence of exempt income, and government grant receipts were treated as capital subsidy and capital in nature. Case-Laws Income Tax Thu, 23 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469928