https://www.taxtmi.com/caselaws?id=798011 Software development services benchmarked under TNMM require comparables aligned with a captive, limited-risk service provider's functions, asset profile and revenue streams; companies undertaking complex end-to-end product engineering, lacking reliable segmental data, or breaching the related-party transaction filter are unsuitable. Delayed trade receivables intrinsically linked to the service transaction affect working capital and profitability. Once a working-capital adjustment is granted, their effect is already reflected in the TNMM analysis, so no separate notional-interest adjustment is warranted. The comparable set, assessed income and consequential demand require recalculation, subject to limited financial verification for one comparable. en-us Tue, 18 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798011 Software development services benchmarked under TNMM require comparables aligned with a captive, limited-risk service provider's functions, asset profile and revenue streams; companies undertaking complex end-to-end product engineering, lacking reliable segmental data, or breaching the related-party transaction filter are unsuitable. Delayed trade receivables intrinsically linked to the service transaction affect working capital and profitability. Once a working-capital adjustment is granted, their effect is already reflected in the TNMM analysis, so no separate notional-interest adjustment is warranted. The comparable set, assessed income and consequential demand require recalculation, subject to limited financial verification for one comparable. Case-Laws Income Tax Tue, 18 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798011