https://www.taxtmi.com/caselaws?id=776249 A salary cross-charge for global sales personnel was held not separately benchmarkable where the software development segment had already been tested at arm's length under TNMM and accepted in assessment; the cost formed part of the operating expenses of that composite segment, so the transfer pricing addition was deleted. Adjustments made in an intimation under section 143(1) were not entertained in this appeal because they were not part of the final assessment order and had to be challenged through the separate statutory remedy against that intimation. en-us Tue, 15 Jul 2025 00:00:00 +0530 Thu, 07 Aug 2025 07:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776249 A salary cross-charge for global sales personnel was held not separately benchmarkable where the software development segment had already been tested at arm's length under TNMM and accepted in assessment; the cost formed part of the operating expenses of that composite segment, so the transfer pricing addition was deleted. Adjustments made in an intimation under section 143(1) were not entertained in this appeal because they were not part of the final assessment order and had to be challenged through the separate statutory remedy against that intimation. Case-Laws Income Tax Tue, 15 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776249