https://www.taxtmi.com/caselaws?id=470719 Transfer-pricing benchmarking should separately assess annual maintenance contract services rendered to independent customers and marketing support services rendered to associated enterprises where their contractual terms, risks and remuneration differ. Marketing support services compensated on a cost-plus basis require actual segmental data for arm's length analysis. For software development services, comparables require functional and financial verification: companies with unexplained abnormal profitability or diversified software-product activities without reliable segmental data should be excluded, while certain companies may require fresh review. A negative working-capital adjustment is inappropriate for a captive cost-plus service provider that bears no working-capital risk, because it would artificially increase the 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 should separately assess annual maintenance contract services rendered to independent customers and marketing support services rendered to associated enterprises where their contractual terms, risks and remuneration differ. Marketing support services compensated on a cost-plus basis require actual segmental data for arm's length analysis. For software development services, comparables require functional and financial verification: companies with unexplained abnormal profitability or diversified software-product activities without reliable segmental data should be excluded, while certain companies may require fresh review. A negative working-capital adjustment is inappropriate for a captive cost-plus service provider that bears no working-capital risk, because it would artificially increase the arm's length margin. Case-Laws Income Tax Wed, 29 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470719