https://www.taxtmi.com/caselaws?id=471075 Transfer-pricing benchmarking of captive software development service providers requires turnover-based and functional comparability. Entities with turnover exceeding ten times that of the tested party, diversified operations, product activities, or materially different functional profiles should be excluded, while suitable comparables should be included for fresh arm's-length computation. A separate adjustment for interest on delayed trade receivables requires verification and should not be made where the delay is already reflected in a working-capital adjustment, as this would duplicate the adjustment. Penalty proceedings require consequential reconsideration after recomputation of the underlying transfer-pricing adjustment. en-us Wed, 24 Sep 2025 00:00:00 +0530 Wed, 19 Aug 2026 18:58:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471075 Transfer-pricing benchmarking of captive software development service providers requires turnover-based and functional comparability. Entities with turnover exceeding ten times that of the tested party, diversified operations, product activities, or materially different functional profiles should be excluded, while suitable comparables should be included for fresh arm's-length computation. A separate adjustment for interest on delayed trade receivables requires verification and should not be made where the delay is already reflected in a working-capital adjustment, as this would duplicate the adjustment. Penalty proceedings require consequential reconsideration after recomputation of the underlying transfer-pricing adjustment. Case-Laws Income Tax Wed, 24 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471075