https://www.taxtmi.com/caselaws?id=798579 Retrospective amendments to the limitation framework in sections 144C and 153, effective from 1 April 2009, place the final assessment order within time. Transfer-pricing benchmarking of software-development and IT-enabled services must rely on contemporaneous functional evidence and reliable segmental data: entities with distinct functions, diversified unsegregated operations, or unreliable related-party transaction information require exclusion, while functionally comparable segregable segments may be included. The distribution transaction's tolerance-band claim requires factual verification of purchase-cost, inventory-to-sales, and arm's-length-price variation conditions; any eligible transaction within the prescribed band requires deletion of the adjustment. Benchmarking must be recomputed using the resulting comparability changes. en-us Mon, 31 Aug 2026 00:00:00 +0530 Wed, 09 Sep 2026 08:20:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798579 Retrospective amendments to the limitation framework in sections 144C and 153, effective from 1 April 2009, place the final assessment order within time. Transfer-pricing benchmarking of software-development and IT-enabled services must rely on contemporaneous functional evidence and reliable segmental data: entities with distinct functions, diversified unsegregated operations, or unreliable related-party transaction information require exclusion, while functionally comparable segregable segments may be included. The distribution transaction's tolerance-band claim requires factual verification of purchase-cost, inventory-to-sales, and arm's-length-price variation conditions; any eligible transaction within the prescribed band requires deletion of the adjustment. Benchmarking must be recomputed using the resulting comparability changes. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798579