https://www.taxtmi.com/caselaws?id=466051 Transfer pricing issues concerning whether AMP payments constitute an international transaction were examined; AMP was treated as not representing an international transaction, with no ALP determination for AMP. Separately, comparability for the software development segment was assessed against a single comparable; the decision applied the tolerance limit in comparability analysis and concluded that the benchmark margin differential fell within the accepted tolerance, resulting in deletion of the upward TP adjustment in the software segment and conferring relief to the taxpayer. en-us Mon, 27 Mar 2023 00:00:00 +0530 Wed, 21 Jan 2026 20:45:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466051 Transfer pricing issues concerning whether AMP payments constitute an international transaction were examined; AMP was treated as not representing an international transaction, with no ALP determination for AMP. Separately, comparability for the software development segment was assessed against a single comparable; the decision applied the tolerance limit in comparability analysis and concluded that the benchmark margin differential fell within the accepted tolerance, resulting in deletion of the upward TP adjustment in the software segment and conferring relief to the taxpayer. Case-Laws Income Tax Mon, 27 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466051