https://www.taxtmi.com/highlights?id=105051 Functional comparability for captive cost-plus ITeS providers requires alignment of scale, brand, intangibles, technology and service profile; materially dissimilar outsourcing, accounting or publishing businesses are excluded, while functionally similar ITeS providers may remain comparable. Companies outside the TPO search matrix cannot be rejected solely on that basis if they satisfy applicable filters, subject to functional, asset and risk analysis and annual-report verification. Delayed associated-enterprise receivables are international transactions requiring separate benchmarking after the comparable credit period, using LIBOR plus an appropriate spread. Foreign-exchange gains on reinstated trade payables and receivables lack the direct and proximate export nexus required for a section 10AA deduction. en-us Fri, 16 Oct 2026 05:20:55 +0530 Fri, 16 Oct 2026 05:20:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105051 Functional comparability for captive cost-plus ITeS providers requires alignment of scale, brand, intangibles, technology and service profile; materially dissimilar outsourcing, accounting or publishing businesses are excluded, while functionally similar ITeS providers may remain comparable. Companies outside the TPO search matrix cannot be rejected solely on that basis if they satisfy applicable filters, subject to functional, asset and risk analysis and annual-report verification. Delayed associated-enterprise receivables are international transactions requiring separate benchmarking after the comparable credit period, using LIBOR plus an appropriate spread. Foreign-exchange gains on reinstated trade payables and receivables lack the direct and proximate export nexus required for a section 10AA deduction. Highlights Income Tax Fri, 16 Oct 2026 05:20:55 +0530 https://www.taxtmi.com/highlights?id=105051