https://www.taxtmi.com/caselaws?id=796393 Segmental results for benchmarking software-development services require factual verification where audited segmental accounts and cost-allocation records are material to determining the arm's length price. Rejection without examining the segmentation methodology on merits is not sustainable; the matter requires verification and recomputation if necessary. Notional interest on associated-enterprise receivables should not be selectively imputed when comparable non-associated-enterprise receivables carry no interest and the associated enterprise's average realisation period falls within the permitted credit period. On those facts, the receivables adjustment cannot survive. en-us Tue, 07 Jul 2026 00:00:00 +0530 Wed, 05 Aug 2026 08:48:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796393 Segmental results for benchmarking software-development services require factual verification where audited segmental accounts and cost-allocation records are material to determining the arm's length price. Rejection without examining the segmentation methodology on merits is not sustainable; the matter requires verification and recomputation if necessary. Notional interest on associated-enterprise receivables should not be selectively imputed when comparable non-associated-enterprise receivables carry no interest and the associated enterprise's average realisation period falls within the permitted credit period. On those facts, the receivables adjustment cannot survive. Case-Laws Income Tax Tue, 07 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796393