https://www.taxtmi.com/caselaws?id=326043 Transfer pricing adjustment for the software licensing segment requires a reasoned rejection of the taxpayer's chosen method, with proper recording of why CUP is not the most appropriate method and why TNMM and comparables are selected; on an unsupported and inconsistent basis, the matter was remitted for fresh adjudication after hearing the assessee. The adjustment must also be confined to the value of international transactions with associated enterprises and cannot be extended to the entire segment turnover, so the scope of adjustment was restricted to AE-related transactions. en-us Wed, 24 Feb 2016 00:00:00 +0530 Tue, 05 Apr 2016 08:12:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326043 Transfer pricing adjustment for the software licensing segment requires a reasoned rejection of the taxpayer's chosen method, with proper recording of why CUP is not the most appropriate method and why TNMM and comparables are selected; on an unsupported and inconsistent basis, the matter was remitted for fresh adjudication after hearing the assessee. The adjustment must also be confined to the value of international transactions with associated enterprises and cannot be extended to the entire segment turnover, so the scope of adjustment was restricted to AE-related transactions. Case-Laws Income Tax Wed, 24 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326043