https://www.taxtmi.com/caselaws?id=798023 Section 144C(13A), retrospectively effective from 1 April 2009, governs limitation and leaves the final assessment within time. Cost-to-cost recovery of withholding tax paid on employee stock options for associated enterprises is unrelated to ITeS and must be excluded from operating income when computing the operating profit-to-operating cost margin. Comparable selection must follow actual functions: voice call-centre, routine BPO, IT service and intellectual-property consultancy entities are materially dissimilar, while the identified knowledge-processing comparable is retained. Delayed receivables are an international transaction, but a working-capital adjustment under TNMM addresses their profitability effect where linked to ITeS, precluding a separate notional-interest adjustment. en-us Mon, 24 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798023 Section 144C(13A), retrospectively effective from 1 April 2009, governs limitation and leaves the final assessment within time. Cost-to-cost recovery of withholding tax paid on employee stock options for associated enterprises is unrelated to ITeS and must be excluded from operating income when computing the operating profit-to-operating cost margin. Comparable selection must follow actual functions: voice call-centre, routine BPO, IT service and intellectual-property consultancy entities are materially dissimilar, while the identified knowledge-processing comparable is retained. Delayed receivables are an international transaction, but a working-capital adjustment under TNMM addresses their profitability effect where linked to ITeS, precluding a separate notional-interest adjustment. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798023