https://www.taxtmi.com/caselaws?id=798551 Internal TNMM for IT services requires separate benchmarking of AE and non-AE segments where their functions and risks differ. Certified segmental results included in transfer-pricing records can support the analysis; audited segmental accounts are not required. An AE captive-service margin within the arm's-length range supports acceptance of the AE segment. Ind AS 32 presentation of CCDs as equity does not change their underlying debt character. Interest remains deductible while CCDs are outstanding, subject to confirmation that no actual conversion or redemption occurred during the relevant year. en-us Mon, 16 Feb 2026 00:00:00 +0530 Wed, 09 Sep 2026 08:20:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798551 Internal TNMM for IT services requires separate benchmarking of AE and non-AE segments where their functions and risks differ. Certified segmental results included in transfer-pricing records can support the analysis; audited segmental accounts are not required. An AE captive-service margin within the arm's-length range supports acceptance of the AE segment. Ind AS 32 presentation of CCDs as equity does not change their underlying debt character. Interest remains deductible while CCDs are outstanding, subject to confirmation that no actual conversion or redemption occurred during the relevant year. Case-Laws Income Tax Mon, 16 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798551