https://www.taxtmi.com/caselaws?id=470719 Transfer-pricing benchmarking cannot aggregate independently negotiated non-associated enterprise annual maintenance contracts, involving market and credit risks, with associated enterprise marketing support services performed on a cost-plus basis; arm's length pricing requires actual segmental data. Comparable selection for software development services requires functional similarity and reliable segmental operating data: diversified software-product companies and entities with unexplained abnormal revenue and profit growth should be excluded, while certain companies require reconsideration of financial and employee-cost data. A fully funded captive cost-plus service provider bearing no working-capital risk should not receive a negative working-capital adjustment, as this would artificially increase its arm's length margin. en-us Wed, 29 Sep 2021 00:00:00 +0530 Wed, 05 Aug 2026 17:05:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470719 Transfer-pricing benchmarking cannot aggregate independently negotiated non-associated enterprise annual maintenance contracts, involving market and credit risks, with associated enterprise marketing support services performed on a cost-plus basis; arm's length pricing requires actual segmental data. Comparable selection for software development services requires functional similarity and reliable segmental operating data: diversified software-product companies and entities with unexplained abnormal revenue and profit growth should be excluded, while certain companies require reconsideration of financial and employee-cost data. A fully funded captive cost-plus service provider bearing no working-capital risk should not receive a negative working-capital adjustment, as this would artificially increase its arm's length margin. Case-Laws Income Tax Wed, 29 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470719