https://www.taxtmi.com/caselaws?id=208605 In determining ALP of international transactions with AEs, the ITAT held that under r.10B(1)(e) TNMM margins of comparables must be adjusted for differences materially affecting net profit; working capital adjustment was therefore directed to be allowed. On import-cost adjustment, the ITAT held such adjustment is permissible on the same r.10B principles, but remitted the matter to the TPO/AO/DRP to verify whether the difference materially affects price/profit under r.10B(3); the ground was allowed pro tanto. On the proviso to s.92C(2), it held the assessee is entitled to the 5% benefit where multiple prices form the arithmetic mean; relief granted. TP adjustment was directed to be computed proportionately to AE-controlled imports, not on entity-level sales; remaining grounds (including export-related TP, TDS/SA credit, and interest) were remitted for recomputation. en-us Wed, 04 Jan 2012 00:00:00 +0530 Wed, 31 Dec 2025 10:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208605 In determining ALP of international transactions with AEs, the ITAT held that under r.10B(1)(e) TNMM margins of comparables must be adjusted for differences materially affecting net profit; working capital adjustment was therefore directed to be allowed. On import-cost adjustment, the ITAT held such adjustment is permissible on the same r.10B principles, but remitted the matter to the TPO/AO/DRP to verify whether the difference materially affects price/profit under r.10B(3); the ground was allowed pro tanto. On the proviso to s.92C(2), it held the assessee is entitled to the 5% benefit where multiple prices form the arithmetic mean; relief granted. TP adjustment was directed to be computed proportionately to AE-controlled imports, not on entity-level sales; remaining grounds (including export-related TP, TDS/SA credit, and interest) were remitted for recomputation. Case-Laws Income Tax Wed, 04 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208605