https://www.taxtmi.com/caselaws?id=372787 Where international sales are benchmarked under TNMM, a separate notional interest adjustment for delayed receivables is not warranted if the effect is already embedded in operating margins, and comparable credit terms for non-associated enterprises support the absence of a separate adjustment. A provision for royalty on bundled software components is not disallowable under section 40(a)(i) merely when booked, because withholding liability arises only when the underlying royalty obligation crystallises on activation of the product. On this reasoning, the transfer pricing adjustment and the royalty-related disallowance were deleted. en-us Fri, 16 Nov 2018 00:00:00 +0530 Sat, 29 Dec 2018 11:33:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=372787 Where international sales are benchmarked under TNMM, a separate notional interest adjustment for delayed receivables is not warranted if the effect is already embedded in operating margins, and comparable credit terms for non-associated enterprises support the absence of a separate adjustment. A provision for royalty on bundled software components is not disallowable under section 40(a)(i) merely when booked, because withholding liability arises only when the underlying royalty obligation crystallises on activation of the product. On this reasoning, the transfer pricing adjustment and the royalty-related disallowance were deleted. Case-Laws Income Tax Fri, 16 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=372787