Comparable selection - Tribunal remanded issue of inclusion of ...

Software company's transfer pricing dispute: Comparable selection, turnover filters, interest rates on delayed payments at issue.

Case Laws Income Tax

August 16, 2024

Comparable selection - Tribunal remanded issue of inclusion of companies to TPO to examine functional comparability after applying applicable filters. If functionally comparable, TPO directed to include for computing ALP. Turnover filter - Tribunal directed TPO to apply turnover filter of ten times and 1/10th on both sides, excluding companies outside this range. Infobeans exclusion - Tribunal upheld exclusion as not a KPO. Delay in receipts - Tribunal directed applying SBI rate of 6% with 60-day credit period for interest on delayed trade receivables, following earlier decisions. ALP - Arm's Length Price, TPO - Transfer Pricing Officer, TNMM - Transactional Net Margin Method, KPO - Knowledge Process Outsourcing, AE - Associated Enterprise.

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Comparable selection - Tribunal remanded issue of inclusion of ...

Software company's transfer pricing dispute: Comparable selection, turnover filters, interest rates on delayed payments at issue.

Case Laws Income Tax

August 16, 2024

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