https://www.taxtmi.com/caselaws?id=798566 Working-capital adjustment for a captive back-office service provider should be allowed on supporting computations, while companies with specialised functions, exceptional events, significant intangibles, substantial outsourcing, abnormal growth or materially different turnover are unsuitable comparables; a reasoned comparable may be retained. Where receivable effects are neutralised through working-capital adjustment and credit policy, notional interest on delayed associated-enterprise receivables duplicates the adjustment unless a distinct international transaction is demonstrated. Unbilled revenue included in total turnover requires reconsideration of parity treatment in export turnover for the Section 10A deduction. Genuine service-cost allocations cannot be assigned a nil arm's length price without evidence that services were not rendered or had no cost. en-us Fri, 14 Aug 2026 00:00:00 +0530 Wed, 09 Sep 2026 10:56:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798566 Working-capital adjustment for a captive back-office service provider should be allowed on supporting computations, while companies with specialised functions, exceptional events, significant intangibles, substantial outsourcing, abnormal growth or materially different turnover are unsuitable comparables; a reasoned comparable may be retained. Where receivable effects are neutralised through working-capital adjustment and credit policy, notional interest on delayed associated-enterprise receivables duplicates the adjustment unless a distinct international transaction is demonstrated. Unbilled revenue included in total turnover requires reconsideration of parity treatment in export turnover for the Section 10A deduction. Genuine service-cost allocations cannot be assigned a nil arm's length price without evidence that services were not rendered or had no cost. Case-Laws Income Tax Fri, 14 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798566