https://www.taxtmi.com/caselaws?id=796798 For software-development-services benchmarking, a ten-times turnover filter on either side of the tested party's turnover excludes entities whose scale-driven efficiencies, market strength and intangibles distort comparability. Functional comparability of entities with diversified technology services requires verification of service mix, revenue composition and a proper FAR analysis. An entity cannot be excluded under a related-party-transaction filter where its annual report shows no such transactions, while insufficiently examined FAR profiles require reconsideration. No interest adjustment arises on trade receivables collected within the permitted credit period based on actual outstanding balances. Notional interest on interest-free loans funded from interest-free funds for commercial expediency is inappropriate where the arrangement is revenue-neutral between Indian taxable entities. en-us Fri, 17 Jul 2026 00:00:00 +0530 Tue, 11 Aug 2026 08:47:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796798 For software-development-services benchmarking, a ten-times turnover filter on either side of the tested party's turnover excludes entities whose scale-driven efficiencies, market strength and intangibles distort comparability. Functional comparability of entities with diversified technology services requires verification of service mix, revenue composition and a proper FAR analysis. An entity cannot be excluded under a related-party-transaction filter where its annual report shows no such transactions, while insufficiently examined FAR profiles require reconsideration. No interest adjustment arises on trade receivables collected within the permitted credit period based on actual outstanding balances. Notional interest on interest-free loans funded from interest-free funds for commercial expediency is inappropriate where the arrangement is revenue-neutral between Indian taxable entities. Case-Laws Income Tax Fri, 17 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796798