https://www.taxtmi.com/caselaws?id=795049 Documented third-party software licence and support costs could not be assigned a nil arm's length price where invoices, licensing agreements, vendor rates and allocation workings established actual receipt and allocation of services; the adjustment was deleted. IS&T benchmarking could not aggregate cost-to-cost vendor recoveries with low-end services contrary to Dispute Resolution Panel directions, and a materially different company was excluded as functionally non-comparable; recomputation was required. The bonus deduction claim, following an earlier disallowance, required verification of records and could be allowed if admissible. en-us Wed, 04 Feb 2026 00:00:00 +0530 Thu, 16 Jul 2026 09:07:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795049 Documented third-party software licence and support costs could not be assigned a nil arm's length price where invoices, licensing agreements, vendor rates and allocation workings established actual receipt and allocation of services; the adjustment was deleted. IS&T benchmarking could not aggregate cost-to-cost vendor recoveries with low-end services contrary to Dispute Resolution Panel directions, and a materially different company was excluded as functionally non-comparable; recomputation was required. The bonus deduction claim, following an earlier disallowance, required verification of records and could be allowed if admissible. Case-Laws Income Tax Wed, 04 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795049