https://www.taxtmi.com/caselaws?id=790830 Where an assessee resold software subscriptions purchased from an associated enterprise to unrelated customers without value addition, it was treated as a stripped-down reseller rather than a marketing support service provider. On that functional profile, the margin from resale, together with operating expenses reflecting the functions performed and risks assumed, supported use of the Transactional Net Margin Method with Berry Ratio as the profit level indicator. The contrary approach adopted by the lower authorities was considered incorrect, and the transfer pricing adjustment was deleted while the assessee's benchmarking method was accepted. en-us Fri, 16 Jan 2026 00:00:00 +0530 Fri, 01 May 2026 10:14:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790830 Where an assessee resold software subscriptions purchased from an associated enterprise to unrelated customers without value addition, it was treated as a stripped-down reseller rather than a marketing support service provider. On that functional profile, the margin from resale, together with operating expenses reflecting the functions performed and risks assumed, supported use of the Transactional Net Margin Method with Berry Ratio as the profit level indicator. The contrary approach adopted by the lower authorities was considered incorrect, and the transfer pricing adjustment was deleted while the assessee's benchmarking method was accepted. Case-Laws Income Tax Fri, 16 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790830