https://www.taxtmi.com/caselaws?id=795352 APA margins apply only to the assessment years covered by the agreement and its specified rollback period; the stated margin could not extend to assessment year 2009-10. Foreign exchange fluctuation intrinsically linked to software development services is treated as operating income. A working capital adjustment may be available where supporting computations are provided and verified. No transfer-pricing adjustment should arise if the verified working-capital-adjusted comparable margin falls within the applicable statutory tolerance range. The claimed short credit for tax deducted at source requires fresh factual verification and de novo determination in accordance with law. en-us Thu, 16 Jul 2026 00:00:00 +0530 Tue, 21 Jul 2026 08:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795352 APA margins apply only to the assessment years covered by the agreement and its specified rollback period; the stated margin could not extend to assessment year 2009-10. Foreign exchange fluctuation intrinsically linked to software development services is treated as operating income. A working capital adjustment may be available where supporting computations are provided and verified. No transfer-pricing adjustment should arise if the verified working-capital-adjusted comparable margin falls within the applicable statutory tolerance range. The claimed short credit for tax deducted at source requires fresh factual verification and de novo determination in accordance with law. Case-Laws Income Tax Thu, 16 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795352