https://www.taxtmi.com/caselaws?id=798730 Overdue receivables arising solely from software development and ITES transactions accepted at arm's length must be assessed within the transfer-pricing analysis of those underlying transactions. Rule 10B requires reasonably accurate adjustments to uncontrolled comparables for material differences affecting price, cost or profit. Denying a working capital adjustment while making a separate notional-interest adjustment for delayed associated-enterprise receivables is inconsistent with that framework. Working capital adjustment must be granted first; once allowed, no separate transfer-pricing adjustment for interest on the overdue receivables is warranted. en-us Thu, 30 Jul 2026 00:00:00 +0530 Fri, 11 Sep 2026 08:13:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798730 Overdue receivables arising solely from software development and ITES transactions accepted at arm's length must be assessed within the transfer-pricing analysis of those underlying transactions. Rule 10B requires reasonably accurate adjustments to uncontrolled comparables for material differences affecting price, cost or profit. Denying a working capital adjustment while making a separate notional-interest adjustment for delayed associated-enterprise receivables is inconsistent with that framework. Working capital adjustment must be granted first; once allowed, no separate transfer-pricing adjustment for interest on the overdue receivables is warranted. Case-Laws Income Tax Thu, 30 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798730