https://www.taxtmi.com/highlights?id=99357 In transfer pricing for resale of software subscriptions, the Tribunal held that the assessee was a limited-risk, stripped-down distributor and not a marketing support service provider, because it bought software subscriptions from its associated enterprise and resold them to unrelated customers without modifying or adding value to the product. On that factual basis, the cost of software licences could not displace Berry ratio as the appropriate base, since the assessee did not own intangibles and earned only a resale margin. TNMM was upheld as the most appropriate method and Berry ratio was accepted as the correct profit level indicator for determining arm's length price, so the transfer pricing adjustment failed. en-us Fri, 01 May 2026 10:14:36 +0530 Fri, 01 May 2026 10:14:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99357 In transfer pricing for resale of software subscriptions, the Tribunal held that the assessee was a limited-risk, stripped-down distributor and not a marketing support service provider, because it bought software subscriptions from its associated enterprise and resold them to unrelated customers without modifying or adding value to the product. On that factual basis, the cost of software licences could not displace Berry ratio as the appropriate base, since the assessee did not own intangibles and earned only a resale margin. TNMM was upheld as the most appropriate method and Berry ratio was accepted as the correct profit level indicator for determining arm's length price, so the transfer pricing adjustment failed. Highlights Income Tax Fri, 01 May 2026 10:14:36 +0530 https://www.taxtmi.com/highlights?id=99357