https://www.taxtmi.com/caselaws?id=798734 Selling commission paid to associated enterprises, when included as an operating cost of a software development services segment benchmarked under the Transactional Net Margin Method, is a closely linked cost and cannot be separately benchmarked at a nil arm's length price. Acceptance of TNMM as the most appropriate method and of the segment's arm's length outcome covers the commission within the operating-cost base used to compute the segment margin. Verification under an appellate direction resulted in deletion of the proposed transfer-pricing adjustment. Consequently, no separate adjustment for the selling commission was warranted. en-us Thu, 27 Aug 2026 00:00:00 +0530 Fri, 11 Sep 2026 08:13:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798734 Selling commission paid to associated enterprises, when included as an operating cost of a software development services segment benchmarked under the Transactional Net Margin Method, is a closely linked cost and cannot be separately benchmarked at a nil arm's length price. Acceptance of TNMM as the most appropriate method and of the segment's arm's length outcome covers the commission within the operating-cost base used to compute the segment margin. Verification under an appellate direction resulted in deletion of the proposed transfer-pricing adjustment. Consequently, no separate adjustment for the selling commission was warranted. Case-Laws Income Tax Thu, 27 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798734