https://www.taxtmi.com/caselaws?id=216229 Transfer pricing assessment concerned determination of arm's length price for cross-border software supply. The transactional net margin method was adopted after cost-plus documentation was inadequate; comparability analysis under rule 10C excluded four alleged comparables as operating in different lines of business, leaving a single comparable. The proviso allowing the arithmetical mean (or assessee's 5% variation) applies only when more than one price is determined by the most appropriate method; it therefore did not apply here, and the ALP was fixed based on the sole comparable, resulting in dismissal of the revenue appeal. en-us Wed, 31 Mar 2010 00:00:00 +0530 Thu, 29 Jan 2026 17:20:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216229 Transfer pricing assessment concerned determination of arm's length price for cross-border software supply. The transactional net margin method was adopted after cost-plus documentation was inadequate; comparability analysis under rule 10C excluded four alleged comparables as operating in different lines of business, leaving a single comparable. The proviso allowing the arithmetical mean (or assessee's 5% variation) applies only when more than one price is determined by the most appropriate method; it therefore did not apply here, and the ALP was fixed based on the sole comparable, resulting in dismissal of the revenue appeal. Case-Laws Income Tax Wed, 31 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216229