TNMM comparability under transfer pricing was applied across...

TNMM comparability under transfer pricing was applied across operating expenses, software services, ITeS, distribution and manufacturing segments, with the Tribunal treating provision for doubtful debts and routine rates and taxes as operating items, revising the comparable sets on functional similarity and turnover filters, and directing gross-margin benchmarking for the distribution segment. It held that working capital differences require adjustment under TNMM and remitted quantification for fresh computation. Delayed receivables were not sustained as a notional interest adjustment on the facts, and the royalty and intra-group service payments were accepted as closely linked business transactions that could not be benchmarked at nil without proper comparability analysis. The disallowance under section 40(a)(ia) was also deleted for lack of proof of TDS liability.

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