https://www.taxtmi.com/caselaws?id=800214 TNMM comparability requires alignment of functions, assets, risks, intangibles and related-party transactions; turnover alone does not justify excluding a company. Software-product, ERP, high-end technology, consultancy, digital-product engineering and IT-enabled-service profiles may be unsuitable for a captive software-development service provider where material differences impair comparability. Rates and taxes must be verified: any rent element remains an operating cost in the operating-margin computation. No interest adjustment arises on associated-enterprise receivables where the contractual credit period has not expired within the relevant year. The arm's-length analysis requires recomputation after applying the operating-cost treatment and revised comparable set. en-us Thu, 10 Sep 2026 00:00:00 +0530 Sat, 03 Oct 2026 09:32:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800214 TNMM comparability requires alignment of functions, assets, risks, intangibles and related-party transactions; turnover alone does not justify excluding a company. Software-product, ERP, high-end technology, consultancy, digital-product engineering and IT-enabled-service profiles may be unsuitable for a captive software-development service provider where material differences impair comparability. Rates and taxes must be verified: any rent element remains an operating cost in the operating-margin computation. No interest adjustment arises on associated-enterprise receivables where the contractual credit period has not expired within the relevant year. The arm's-length analysis requires recomputation after applying the operating-cost treatment and revised comparable set. Case-Laws Income Tax Thu, 10 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800214