https://www.taxtmi.com/caselaws?id=122426 Comparable uncontrolled price analysis requires materially similar quantity, market conditions and customer profile; isolated third-party sales on different commercial terms are not a reliable benchmark, so the transfer pricing adjustment was deleted. Interest on fixed deposits linked to overdraft facilities, and dividend from shares subscribed to obtain banking facilities, were treated as business income because of their direct business nexus. For export deduction purposes, only net interest was to be considered where interest income and expenditure were inextricably linked, and the appellate relief to the assessee was maintained. en-us Fri, 26 Mar 2010 00:00:00 +0530 Fri, 15 Sep 2023 17:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122426 Comparable uncontrolled price analysis requires materially similar quantity, market conditions and customer profile; isolated third-party sales on different commercial terms are not a reliable benchmark, so the transfer pricing adjustment was deleted. Interest on fixed deposits linked to overdraft facilities, and dividend from shares subscribed to obtain banking facilities, were treated as business income because of their direct business nexus. For export deduction purposes, only net interest was to be considered where interest income and expenditure were inextricably linked, and the appellate relief to the assessee was maintained. Case-Laws Income Tax Fri, 26 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122426