https://www.taxtmi.com/highlights?id=103273 Captive contract software-development services are benchmarked against companies performing comparable software-development functions, assets and risks; product-development businesses, complex digital-product providers and companies lacking relevant segmental information are unsuitable. Companies earning software-development service revenue may remain comparable where no material functional difference is established, while entities exceeding the applicable related-party transaction filter must be excluded. Where delayed trade receivables arise solely from the service transaction benchmarked under TNMM, they require combined benchmarking. Working-capital adjustment for material differences subsumes the receivables effect, so separate notiona..... en-us Tue, 01 Sep 2026 08:26:22 +0530 Tue, 01 Sep 2026 08:26:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103273 Captive contract software-development services are benchmarked against companies performing comparable software-development functions, assets and risks; product-development businesses, complex digital-product providers and companies lacking relevant segmental information are unsuitable. Companies earning software-development service revenue may remain comparable where no material functional difference is established, while entities exceeding the applicable related-party transaction filter must be excluded. Where delayed trade receivables arise solely from the service transaction benchmarked under TNMM, they require combined benchmarking. Working-capital adjustment for material differences subsumes the receivables effect, so separate notiona..... Highlights Income Tax Tue, 01 Sep 2026 08:26:22 +0530 https://www.taxtmi.com/highlights?id=103273