https://www.taxtmi.com/caselaws?id=799438 Section 92C(3) permits rejection of a transfer pricing analysis only where the data used to determine the arm's length price is unreliable or incorrect. Modification of comparability filters alone does not justify discarding a study when its functional analysis, tested party, databases, search methodology and contractual terms are undisputed. The arm's length price for software development services requires re-examination using the taxpayer's database, modified filters and accept-reject matrix. Delayed associated-enterprise receivables can require a separate interest adjustment unless aggregated in transactional net margin method margins after working-capital adjustment; associated-enterprise payables cannot automatically be set off against receivables. en-us Thu, 10 Sep 2026 00:00:00 +0530 Tue, 22 Sep 2026 08:17:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799438 Section 92C(3) permits rejection of a transfer pricing analysis only where the data used to determine the arm's length price is unreliable or incorrect. Modification of comparability filters alone does not justify discarding a study when its functional analysis, tested party, databases, search methodology and contractual terms are undisputed. The arm's length price for software development services requires re-examination using the taxpayer's database, modified filters and accept-reject matrix. Delayed associated-enterprise receivables can require a separate interest adjustment unless aggregated in transactional net margin method margins after working-capital adjustment; associated-enterprise payables cannot automatically be set off against receivables. Case-Laws Income Tax Thu, 10 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799438