https://www.taxtmi.com/caselaws?id=798024 Transfer-pricing adjustments for US tax-return preparation and secondment services require fresh verification of any COVID-19 adjustment through evidence of exceptional costs and their differing impact from comparables. Export incentives, foreign-exchange items connected with revenue transactions, and depreciation on deployed assets must receive consistent operating treatment for the tested party and comparables; recomputation is required on that basis. For software support services, employee-cost differences alone do not invalidate an internal CUP; functional, contractual and market comparability must be examined before selecting TNMM or another appropriate method. The assessment remains within limitation where the draft order was timely and the final order followed DRP directions within the prescribed period. en-us Tue, 25 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798024 Transfer-pricing adjustments for US tax-return preparation and secondment services require fresh verification of any COVID-19 adjustment through evidence of exceptional costs and their differing impact from comparables. Export incentives, foreign-exchange items connected with revenue transactions, and depreciation on deployed assets must receive consistent operating treatment for the tested party and comparables; recomputation is required on that basis. For software support services, employee-cost differences alone do not invalidate an internal CUP; functional, contractual and market comparability must be examined before selecting TNMM or another appropriate method. The assessment remains within limitation where the draft order was timely and the final order followed DRP directions within the prescribed period. Case-Laws Income Tax Tue, 25 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798024