https://www.taxtmi.com/caselaws?id=330063 Rule 10B(1)(e) requires the tested party and comparables to be measured on the same profit base under TNMM. The assessee's indenting activity, carried on as a commission agent, and its buy-sell activity, carried on as principal with inventories and debtors, were materially different business models with different operating cost bases. Commission agency does not include cost of goods sold, while trading does, so both activities could not be benchmarked together on one common PLI and operating base. Combined benchmarking was therefore incorrect, and separate arm's length price determination for each transaction set was required. en-us Tue, 09 Feb 2016 00:00:00 +0530 Sat, 16 Jul 2016 12:36:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330063 Rule 10B(1)(e) requires the tested party and comparables to be measured on the same profit base under TNMM. The assessee's indenting activity, carried on as a commission agent, and its buy-sell activity, carried on as principal with inventories and debtors, were materially different business models with different operating cost bases. Commission agency does not include cost of goods sold, while trading does, so both activities could not be benchmarked together on one common PLI and operating base. Combined benchmarking was therefore incorrect, and separate arm's length price determination for each transaction set was required. Case-Laws Income Tax Tue, 09 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330063