https://www.taxtmi.com/caselaws?id=210938 Transfer-pricing analysis of sales to associated enterprises compares the operating profit margin on the relevant international transactions with accepted margins from comparable periods. Where the combined margin is higher and no evidence shows a lower margin on associated-enterprise transactions, an arm's length price adjustment is not supported. Once an international sale price is accepted as arm's length, delayed recovery of sale proceeds does not constitute a separate interest transaction warranting a notional-interest adjustment. Comparable payment delays from non-associated enterprises without interest charges further negate a selective adjustment, and the CUP method does not justify an additional charge. en-us Wed, 22 Feb 2012 00:00:00 +0530 Fri, 26 Aug 2016 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210938 Transfer-pricing analysis of sales to associated enterprises compares the operating profit margin on the relevant international transactions with accepted margins from comparable periods. Where the combined margin is higher and no evidence shows a lower margin on associated-enterprise transactions, an arm's length price adjustment is not supported. Once an international sale price is accepted as arm's length, delayed recovery of sale proceeds does not constitute a separate interest transaction warranting a notional-interest adjustment. Comparable payment delays from non-associated enterprises without interest charges further negate a selective adjustment, and the CUP method does not justify an additional charge. Case-Laws Income Tax Wed, 22 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210938