https://www.taxtmi.com/caselaws?id=243434 Transfer pricing adjustments under TNMM should be confined to turnover attributable to purchases from an associated enterprise where only that portion involves international transactions. Comparables with related-party transactions exceeding the accepted threshold should be excluded, while customs valuation cannot substitute transfer-pricing comparability because the two regimes have distinct purposes and methodologies. The tolerance under the proviso to Section 92C(2) applies only where the transaction-price variation falls within the prescribed band. Working-capital, customs-duty and start-up adjustments require evidence of their quantifiable effect on margins. Income accrues when an enforceable right to claim arises, and software-payment withholding depends on whether the payment is for packaged software or royalty-like rights. en-us Wed, 14 Aug 2013 00:00:00 +0530 Mon, 02 Feb 2026 12:47:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243434 Transfer pricing adjustments under TNMM should be confined to turnover attributable to purchases from an associated enterprise where only that portion involves international transactions. Comparables with related-party transactions exceeding the accepted threshold should be excluded, while customs valuation cannot substitute transfer-pricing comparability because the two regimes have distinct purposes and methodologies. The tolerance under the proviso to Section 92C(2) applies only where the transaction-price variation falls within the prescribed band. Working-capital, customs-duty and start-up adjustments require evidence of their quantifiable effect on margins. Income accrues when an enforceable right to claim arises, and software-payment withholding depends on whether the payment is for packaged software or royalty-like rights. Case-Laws Income Tax Wed, 14 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243434