https://www.taxtmi.com/caselaws?id=268994 Transfer pricing adjustment on royalty was unwarranted where the assessee benchmarked the payment under TNMM, showed higher operating margins than comparables, and supported the shift from Indian published price to actual sales by regulatory and commercial changes; the TPO's unsupported substitute benchmark could not justify the addition. Prior period export income linked to the eligible unit could be considered for section 10A relief, subject to factual verification of receipt timing and compliance. Section 10A deduction for the software development units was also upheld because eligibility had been accepted in earlier years on identical facts and no distinguishing material was shown. en-us Wed, 14 Oct 2015 00:00:00 +0530 Sat, 05 Dec 2015 11:07:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=268994 Transfer pricing adjustment on royalty was unwarranted where the assessee benchmarked the payment under TNMM, showed higher operating margins than comparables, and supported the shift from Indian published price to actual sales by regulatory and commercial changes; the TPO's unsupported substitute benchmark could not justify the addition. Prior period export income linked to the eligible unit could be considered for section 10A relief, subject to factual verification of receipt timing and compliance. Section 10A deduction for the software development units was also upheld because eligibility had been accepted in earlier years on identical facts and no distinguishing material was shown. Case-Laws Income Tax Wed, 14 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=268994