https://www.taxtmi.com/caselaws?id=794907 Transfer pricing analysis for a captive software development service provider treats turnover as a material comparability filter under the Transactional Net Margin Method. Companies exceeding the accepted Rs. 200 crore threshold may be excluded where differences in size and scale materially affect profit margins, requiring recomputation of the arm's length price. Outstanding receivables from an associated enterprise in foreign currency may constitute a separate international transaction under Section 92B. Any adjustment for delayed receivables should use an appropriate foreign-currency benchmark; the notes identify LIBOR plus 2% as the applicable standard in the discussed context. The remaining non-pressed or kept-open grounds are outside scope. en-us Mon, 29 Jun 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794907 Transfer pricing analysis for a captive software development service provider treats turnover as a material comparability filter under the Transactional Net Margin Method. Companies exceeding the accepted Rs. 200 crore threshold may be excluded where differences in size and scale materially affect profit margins, requiring recomputation of the arm's length price. Outstanding receivables from an associated enterprise in foreign currency may constitute a separate international transaction under Section 92B. Any adjustment for delayed receivables should use an appropriate foreign-currency benchmark; the notes identify LIBOR plus 2% as the applicable standard in the discussed context. The remaining non-pressed or kept-open grounds are outside scope. Case-Laws Income Tax Mon, 29 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794907