https://www.taxtmi.com/caselaws?id=796511 Transfer-pricing benchmarking confines adjustments in the manufacturing segment to controlled international transactions with associated enterprises, rather than total segment turnover. Functionally dissimilar software-product, R&D-intensive and intangible-owning companies should be excluded, while companies predominantly providing software development, implementation, testing, support or maintenance services may be included where comparable. Working-capital, capacity-utilisation and non-cenvatable customs-duty adjustments require examination of material cost or profit differences; capacity data may be obtained from comparables where necessary. Foreign-exchange fluctuations linked to import-intensive operations are operating items, while acquisition-related goodwill amortisation is non-operating. Licence or royalty payments incurred in ordinary business and scientifically estimated warranty provisions supported by historical experience qualify as revenue deductions. en-us Thu, 23 Jul 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796511 Transfer-pricing benchmarking confines adjustments in the manufacturing segment to controlled international transactions with associated enterprises, rather than total segment turnover. Functionally dissimilar software-product, R&D-intensive and intangible-owning companies should be excluded, while companies predominantly providing software development, implementation, testing, support or maintenance services may be included where comparable. Working-capital, capacity-utilisation and non-cenvatable customs-duty adjustments require examination of material cost or profit differences; capacity data may be obtained from comparables where necessary. Foreign-exchange fluctuations linked to import-intensive operations are operating items, while acquisition-related goodwill amortisation is non-operating. Licence or royalty payments incurred in ordinary business and scientifically estimated warranty provisions supported by historical experience qualify as revenue deductions. Case-Laws Income Tax Thu, 23 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796511