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TNMM benchmarking required exclusion of functionally dissimilar,...

TNMM functional comparability drives exclusions, current-year recession margins, operating-income treatment, and deletion of interest imputation on debt-free receivables.

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Income Tax September 9, 2026 Case Laws AT
TNMM benchmarking required exclusion of functionally dissimilar, diversified, and unsegmented companies from the comparable set for manufacturing and engineering-estimation segments. Intra-group support-service charges required fresh verification of evidence showing benefits received and benchmarking under TNMM; the issue was remanded. Business-connected reversals, miscellaneous income, foreign-exchange gains and export incentives were treated as operating income where related expenditure had been treated as operating, increasing the profit level indicator. In the extraordinary COVID-affected year, current-year margins of final comparables were required for comparison rather than weighted averages including normal years. Interest on overdue associated-enterprise receivables was not imputable where audited accounts showed the taxpayer was debt-free and lease liabilities were not borrowings.

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Acts Income Tax