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    Pass-through LLC self-dealing defeats transfer pricing adjustment; linked receivables and profit recomputation were also deleted.
    Transfer pricing comparability: predominantly manufacturing comparables were excluded, and IT support charges were not fixed at nil.
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Income-tax Rules, 2026 prescribe comprehensive operational...

Fair market value and income attribution rules set methodology for valuation, transfer pricing and taxation of cross-border transfers.

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Income Tax March 21, 2026 Notifications
Income-tax Rules, 2026 prescribe comprehensive operational measures: definitions and commencement; domestic dividend declaration and payment requirements; conditions and procedure for notification of recognised stock exchanges; valuation and fair market value methodologies for shares, firms and foreign entities and formulae for attributing income to assets in India; procedures for notification of zero coupon bonds and associated investment and reporting conditions; computation rules for period of holding and capital gains; residence and stay computation for seafarers; extensive transfer pricing framework including comparability, most-appropriate-method selection, dataset and arm's-length range rules, safe-harbour parameters and advance pricing agreement procedures; perquisites valuation, deduction, audit and reporting forms and multiple sectoral procedural provisions and prescribed forms.

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Acts Income Tax