https://www.taxtmi.com/caselaws?id=790877 Under TNMM benchmarking, a materially distortive item affecting the tested party's profit level indicator may be adjusted if the adjustment is reasonably accurate under Rule 10B, and depreciation linked to capitalised in-house software was treated as such a difference. The note states that the software depreciation materially affected the assessee's margin in the relevant year, so its exclusion from PLI computation was upheld and the margin was to be recomputed. It also explains that comparability must reflect functions, assets, risks and turnover, leading to exclusion of very high-turnover comparables. Functional dissimilarity objections were not finally resolved and were remitted for fresh factual examination. en-us Wed, 11 Feb 2026 00:00:00 +0530 Sat, 02 May 2026 07:40:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790877 Under TNMM benchmarking, a materially distortive item affecting the tested party's profit level indicator may be adjusted if the adjustment is reasonably accurate under Rule 10B, and depreciation linked to capitalised in-house software was treated as such a difference. The note states that the software depreciation materially affected the assessee's margin in the relevant year, so its exclusion from PLI computation was upheld and the margin was to be recomputed. It also explains that comparability must reflect functions, assets, risks and turnover, leading to exclusion of very high-turnover comparables. Functional dissimilarity objections were not finally resolved and were remitted for fresh factual examination. Case-Laws Income Tax Wed, 11 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790877