https://www.taxtmi.com/caselaws?id=792713 Transfer pricing disputes concerning ITES and software development segments were addressed by applying the Tribunal's earlier year findings, including acceptance of the assessee's margin and rejection of the revised comparability exercise, so the segment adjustment was deleted. The notional interest addition on outstanding receivables from associated enterprises was also restricted in line with the prior MAP-based approach and was not sustained as made. On imported fixed assets, the Tribunal rejected a nil arm's length valuation where a recognised customs valuation existed, and the related adjustment was deleted. The overall result was complete relief to the assessee on the recurring transfer pricing issues. en-us Fri, 29 May 2026 00:00:00 +0530 Tue, 02 Jun 2026 08:47:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792713 Transfer pricing disputes concerning ITES and software development segments were addressed by applying the Tribunal's earlier year findings, including acceptance of the assessee's margin and rejection of the revised comparability exercise, so the segment adjustment was deleted. The notional interest addition on outstanding receivables from associated enterprises was also restricted in line with the prior MAP-based approach and was not sustained as made. On imported fixed assets, the Tribunal rejected a nil arm's length valuation where a recognised customs valuation existed, and the related adjustment was deleted. The overall result was complete relief to the assessee on the recurring transfer pricing issues. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792713