https://www.taxtmi.com/caselaws?id=799285 For software development services, the employee-cost-to-sales filter applies within a 50%-80% range, requiring a fresh transfer-pricing computation. Companies lacking segmental data, those affected by extraordinary amalgamation, and entities performing programming or consultancy functions outside the relevant segment are excluded from the comparable set. Outstanding trade receivables are international transactions, but an interest adjustment cannot stand where the Comparable Uncontrolled Price method lacks segmental comparable evidence or supporting trends. Working-capital effects on pricing and profitability require fresh examination when determining the arm's length price. The resulting determination uses the revised filter and comparable set, deletes the receivables-interest adjustment, and reconsiders the working-capital adjustment. en-us Thu, 30 Jul 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799285 For software development services, the employee-cost-to-sales filter applies within a 50%-80% range, requiring a fresh transfer-pricing computation. Companies lacking segmental data, those affected by extraordinary amalgamation, and entities performing programming or consultancy functions outside the relevant segment are excluded from the comparable set. Outstanding trade receivables are international transactions, but an interest adjustment cannot stand where the Comparable Uncontrolled Price method lacks segmental comparable evidence or supporting trends. Working-capital effects on pricing and profitability require fresh examination when determining the arm's length price. The resulting determination uses the revised filter and comparable set, deletes the receivables-interest adjustment, and reconsiders the working-capital adjustment. Case-Laws Income Tax Thu, 30 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799285