https://www.taxtmi.com/caselaws?id=801064 High-turnover, branded companies with materially different scale, brand value, operational capacity, and functions-assets-risks profile are not comparable to a captive software development service provider and should be excluded in determining the arm's-length price. Interest on delayed associated-enterprise receivables must be benchmarked by reference to the invoice currency. Where invoices are USD-denominated, LIBOR plus an appropriate mark-up, or another suitable currency-appropriate rate, applies rather than the SBI rate. The transfer-pricing computation consequently requires revised comparables and a currency-aligned interest benchmark. en-us Tue, 29 Sep 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801064 High-turnover, branded companies with materially different scale, brand value, operational capacity, and functions-assets-risks profile are not comparable to a captive software development service provider and should be excluded in determining the arm's-length price. Interest on delayed associated-enterprise receivables must be benchmarked by reference to the invoice currency. Where invoices are USD-denominated, LIBOR plus an appropriate mark-up, or another suitable currency-appropriate rate, applies rather than the SBI rate. The transfer-pricing computation consequently requires revised comparables and a currency-aligned interest benchmark. Case-Laws Income Tax Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801064