https://www.taxtmi.com/caselaws?id=374477 Transfer pricing analysis for software distribution and software development segments turned on segmental cost allocation, comparable selection, and operating margin computation. A consistently followed cost-allocation method backed by the service arrangement and higher-than-comparable margins supported exclusion of the software distribution adjustment. Current-year loss alone was held insufficient to reject a comparable absent persistent losses or functional defect, and contemporaneous data was preferred over multiple-year data for benchmarking. Forex exchange fluctuation was treated as operating income, while product-development and other functionally dissimilar companies were excluded from the software development comparable set, leading to deletion of the related adjustment. en-us Tue, 01 Jan 2019 00:00:00 +0530 Thu, 31 Jan 2019 15:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=374477 Transfer pricing analysis for software distribution and software development segments turned on segmental cost allocation, comparable selection, and operating margin computation. A consistently followed cost-allocation method backed by the service arrangement and higher-than-comparable margins supported exclusion of the software distribution adjustment. Current-year loss alone was held insufficient to reject a comparable absent persistent losses or functional defect, and contemporaneous data was preferred over multiple-year data for benchmarking. Forex exchange fluctuation was treated as operating income, while product-development and other functionally dissimilar companies were excluded from the software development comparable set, leading to deletion of the related adjustment. Case-Laws Income Tax Tue, 01 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374477