https://www.taxtmi.com/caselaws?id=789954 Transfer pricing comparables in the distribution segment must be functionally similar, so full-fledged channel and content owner entities could not be used against a software distribution activity; the adjustment was deleted and software distribution comparables were retained. Where working capital adjustment already subsumes the effect of receivables and payables in the benchmarking analysis, no separate notional interest adjustment is warranted on outstanding receivables from associated enterprises; that addition was also deleted. The assessee succeeded on both transfer pricing grounds and the full addition was set aside. en-us Fri, 10 Apr 2026 00:00:00 +0530 Fri, 17 Apr 2026 08:21:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789954 Transfer pricing comparables in the distribution segment must be functionally similar, so full-fledged channel and content owner entities could not be used against a software distribution activity; the adjustment was deleted and software distribution comparables were retained. Where working capital adjustment already subsumes the effect of receivables and payables in the benchmarking analysis, no separate notional interest adjustment is warranted on outstanding receivables from associated enterprises; that addition was also deleted. The assessee succeeded on both transfer pricing grounds and the full addition was set aside. Case-Laws Income Tax Fri, 10 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789954