https://www.taxtmi.com/highlights?id=103281 Retrospective insertion of section 144C(13A) places the final assessment order within the prescribed limitation period, rejecting the time-bar challenge. Cost-to-cost recovery of withholding tax paid for associated enterprises' restricted stock units is non-operating because it is unrelated to the assessee's ITeS services, and must be excluded from its operating margin. Voice-based call-centre, general IT/BPO, technical-helpdesk and intellectual-property consultancy providers are functionally incomparable with diversified technical ITeS services, while knowledge-processing services may remain comparable. Delayed associated-enterprise receivables, though international transactions, require combined benchmarking with the underlying ITeS transaction; once a working-capital adjustment is granted under TNMM, separate notional interest is unwarranted. en-us Tue, 01 Sep 2026 08:26:22 +0530 Tue, 01 Sep 2026 08:26:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103281 Retrospective insertion of section 144C(13A) places the final assessment order within the prescribed limitation period, rejecting the time-bar challenge. Cost-to-cost recovery of withholding tax paid for associated enterprises' restricted stock units is non-operating because it is unrelated to the assessee's ITeS services, and must be excluded from its operating margin. Voice-based call-centre, general IT/BPO, technical-helpdesk and intellectual-property consultancy providers are functionally incomparable with diversified technical ITeS services, while knowledge-processing services may remain comparable. Delayed associated-enterprise receivables, though international transactions, require combined benchmarking with the underlying ITeS transaction; once a working-capital adjustment is granted under TNMM, separate notional interest is unwarranted. Highlights Income Tax Tue, 01 Sep 2026 08:26:22 +0530 https://www.taxtmi.com/highlights?id=103281