https://www.taxtmi.com/caselaws?id=798577 Cost Plus Method, supported by an internal comparable involving identical software development services at the same mark-up, provides a reliable arm's-length benchmark where functions, assets and accounting norms align. A profit-based method cannot replace it without cogent reasons showing the traditional method's inapplicability and the substituted method's superior appropriateness. On that approach, the software-services adjustment was deleted. Comparable non-charging of interest to unrelated parties supports no arm's-length interest adjustment on delayed associated-enterprise receivables; that adjustment was also deleted. 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=798577 Cost Plus Method, supported by an internal comparable involving identical software development services at the same mark-up, provides a reliable arm's-length benchmark where functions, assets and accounting norms align. A profit-based method cannot replace it without cogent reasons showing the traditional method's inapplicability and the substituted method's superior appropriateness. On that approach, the software-services adjustment was deleted. Comparable non-charging of interest to unrelated parties supports no arm's-length interest adjustment on delayed associated-enterprise receivables; that adjustment was also deleted. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798577