https://www.taxtmi.com/highlights?id=103948 Transfer-pricing benchmarking of software development services applies an employee-cost-to-sales filter within 50% to 80%, requiring recomputation of the arm's length price on that basis. Comparables without segmental results, entities affected by an extraordinary amalgamation, and businesses performing materially different functions are excluded. Overdue associated-enterprise receivables are international transactions, but an interest adjustment under the CUP method requires identified segmental comparables, supporting material, and computation consistent with segmental trends; an unsupported adjustment is deleted. Working-capital differences require fresh examination under applicable transfer-pricing principles. en-us Sat, 19 Sep 2026 08:20:50 +0530 Sat, 19 Sep 2026 08:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103948 Transfer-pricing benchmarking of software development services applies an employee-cost-to-sales filter within 50% to 80%, requiring recomputation of the arm's length price on that basis. Comparables without segmental results, entities affected by an extraordinary amalgamation, and businesses performing materially different functions are excluded. Overdue associated-enterprise receivables are international transactions, but an interest adjustment under the CUP method requires identified segmental comparables, supporting material, and computation consistent with segmental trends; an unsupported adjustment is deleted. Working-capital differences require fresh examination under applicable transfer-pricing principles. Highlights Income Tax Sat, 19 Sep 2026 08:20:50 +0530 https://www.taxtmi.com/highlights?id=103948