Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verification.

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....Software sub-licensing was treated as provision of services rather than wholesale trading for transfer-pricing tolerance purposes. With four comparable companies in the final dataset, Rule 10CA(7) applied, and the one per cent variation reserved for wholesale trading did not apply because the activity neither involved goods trading nor met inventory conditions. The difference between the arm's length price and transaction price fell within the applicable three per cent range, so the transfer-pricing adjustment was deleted and benchmarking and comparable challenges required no decision. Claimed TDS short credit requires record verification and allowance in accordance with law.....