https://www.taxtmi.com/caselaws?id=796081 Transfer-pricing comparability under TNMM requires exclusion of companies that fail the applied related-party-transactions filter or lack segmental results for diversified operations. I-Design Engineering Solutions Ltd. exceeded the relevant related-party-transactions threshold, while Tata Consulting Engineers Ltd. undertook varied engineering, project-management and construction-management activities without separate engineering-design segment results. The arm's length price requires recomputation after their exclusion. Payments for software to an associated enterprise are not subject to withholding-based disallowance where they are not chargeable to tax in the recipient's hands and do not constitute royalty under the applicable tax treaty. en-us Tue, 07 Jul 2026 00:00:00 +0530 Fri, 31 Jul 2026 08:27:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796081 Transfer-pricing comparability under TNMM requires exclusion of companies that fail the applied related-party-transactions filter or lack segmental results for diversified operations. I-Design Engineering Solutions Ltd. exceeded the relevant related-party-transactions threshold, while Tata Consulting Engineers Ltd. undertook varied engineering, project-management and construction-management activities without separate engineering-design segment results. The arm's length price requires recomputation after their exclusion. Payments for software to an associated enterprise are not subject to withholding-based disallowance where they are not chargeable to tax in the recipient's hands and do not constitute royalty under the applicable tax treaty. Case-Laws Income Tax Tue, 07 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796081