https://www.taxtmi.com/caselaws?id=796392 Under TNMM, product-development expenditure for an unfinished product intended for the non-AE segment, with no related revenue or nexus to tested AE transactions, is treated as non-operating and excluded from operating cost. Acquisition and integration expenditure directed to non-AE business expansion, including due diligence, compliance, retention and consolidation costs, is likewise excluded where unconnected with AE software-development transactions. Internal TNMM is unsuitable where domestic non-AE transactions and export AE transactions lack sufficient comparability. The AE segment may instead be benchmarked against suitable external comparables, and exclusion of unrelated non-operating costs supports satisfaction of the arm's-length standard. en-us Mon, 06 Jul 2026 00:00:00 +0530 Wed, 05 Aug 2026 08:48:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796392 Under TNMM, product-development expenditure for an unfinished product intended for the non-AE segment, with no related revenue or nexus to tested AE transactions, is treated as non-operating and excluded from operating cost. Acquisition and integration expenditure directed to non-AE business expansion, including due diligence, compliance, retention and consolidation costs, is likewise excluded where unconnected with AE software-development transactions. Internal TNMM is unsuitable where domestic non-AE transactions and export AE transactions lack sufficient comparability. The AE segment may instead be benchmarked against suitable external comparables, and exclusion of unrelated non-operating costs supports satisfaction of the arm's-length standard. Case-Laws Income Tax Mon, 06 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796392