https://www.taxtmi.com/caselaws?id=795691 Transfer-pricing comparability in software development services should account for turnover, with entities above the stated upper threshold excluded where they are not comparable to a limited-risk captive provider. Salary cross-charges included in an aggregated segment accepted under TNMM cannot be separately valued at nil without comparable evidence that an independent enterprise would not pay; the benefit test does not replace commercial judgment. Reversal or write-off of provisions previously disallowed may be deducted after verification to prevent double disallowance. Foreign tax credit may be supported by alternative evidence of foreign tax payment, and absence of a foreign tax-authority certificate alone should not defeat the claim. en-us Fri, 03 Jul 2026 00:00:00 +0530 Sat, 25 Jul 2026 08:54:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795691 Transfer-pricing comparability in software development services should account for turnover, with entities above the stated upper threshold excluded where they are not comparable to a limited-risk captive provider. Salary cross-charges included in an aggregated segment accepted under TNMM cannot be separately valued at nil without comparable evidence that an independent enterprise would not pay; the benefit test does not replace commercial judgment. Reversal or write-off of provisions previously disallowed may be deducted after verification to prevent double disallowance. Foreign tax credit may be supported by alternative evidence of foreign tax payment, and absence of a foreign tax-authority certificate alone should not defeat the claim. Case-Laws Income Tax Fri, 03 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795691