https://www.taxtmi.com/caselaws?id=801174 Transfer-pricing comparability requires functional alignment across services, scale, business model and intangibles. Entities with diversified integrated operations, significant brand value, or accounting, publishing and platform services are unsuitable for routine captive IT-enabled services, whereas functionally similar IT-enabled providers may remain comparable despite absent segmental data. Companies satisfying applicable filters cannot be rejected merely because they are absent from the TPO search matrix; annual reports and FAR analysis require verification. Associated-enterprise receivables are international transactions requiring separate arm's-length benchmarking after the allowed credit period, using LIBOR plus 200 basis points following 60 days. Foreign-exchange gains on restated export receivables and payables lack the direct and proximate export-income nexus required for Section 10AA deduction. en-us Wed, 30 Sep 2026 00:00:00 +0530 Fri, 16 Oct 2026 05:20:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801174 Transfer-pricing comparability requires functional alignment across services, scale, business model and intangibles. Entities with diversified integrated operations, significant brand value, or accounting, publishing and platform services are unsuitable for routine captive IT-enabled services, whereas functionally similar IT-enabled providers may remain comparable despite absent segmental data. Companies satisfying applicable filters cannot be rejected merely because they are absent from the TPO search matrix; annual reports and FAR analysis require verification. Associated-enterprise receivables are international transactions requiring separate arm's-length benchmarking after the allowed credit period, using LIBOR plus 200 basis points following 60 days. Foreign-exchange gains on restated export receivables and payables lack the direct and proximate export-income nexus required for Section 10AA deduction. Case-Laws Income Tax Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801174