{"query":"What is the transfer pricing safe harbour floor for software development service","matches":[{"id":"tp_safe_harbour_swd_floor","question":"What is the transfer pricing safe harbour floor for software development services?","answer":"17% operating margin for software development / ITES where the transaction value is up to ₹100 crore; 18% above ₹100 crore; KPO 18–24% by employee-cost intensity (Rule 10TD). A margin below the floor is not protected — a validly elected margin at or above it forecloses TPO benchmarking of that transaction.","pinpoint":"Rule 10TD, Income-tax Rules","confidence":"administrative","as_at":"14 Aug 2026","match_score":1,"value":17}],"engine":"deterministic","llm_in_path":false}