Under TNMM, a Basmati rice trader that only procures and exports...

Under TNMM, a Basmati rice trader that only procures and exports rice to its associated enterprise should be benchmarked against entities with comparable trading functions, assets and risks. Diversified commodity trading and rice milling, processing or manufacturing companies were treated as functionally dissimilar and excluded; milling and processing, rather than non-Basmati dealings or profitability alone, determined exclusion. Segmental trading results of a diversified company required reconsideration where trading represented its predominant revenue. Cash discounts reducing rice purchase cost and export incentives from licence sales were treated as operating income, since their exclusion would distort the operating-profit comparison. The transfer-pricing adjustment required recomputation on these bases.