https://www.taxtmi.com/caselaws?id=277721 Transfer pricing under the transactional net margin method must be based on year-specific functional comparability, and companies with diversified operations or materially different functions may be excluded where uniform revenue-based allocation of common expenses is unreliable. Arm's length adjustment is confined to international transactions with associated enterprises, so a composite adjustment on consolidated turnover including non-AE transactions is impermissible. Administrative fees paid to overseas group entities were held not subject to disallowance where no technical knowledge was made available and the facts matched an earlier year. Printers were treated as computer peripherals eligible for higher depreciation, with opening written down value to be aligned with any accepted prior-year disallowance. Interest under section 234A required factual verification and recomputation if warranted. en-us Thu, 18 Jan 2018 00:00:00 +0530 Thu, 20 Dec 2018 05:56:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277721 Transfer pricing under the transactional net margin method must be based on year-specific functional comparability, and companies with diversified operations or materially different functions may be excluded where uniform revenue-based allocation of common expenses is unreliable. Arm's length adjustment is confined to international transactions with associated enterprises, so a composite adjustment on consolidated turnover including non-AE transactions is impermissible. Administrative fees paid to overseas group entities were held not subject to disallowance where no technical knowledge was made available and the facts matched an earlier year. Printers were treated as computer peripherals eligible for higher depreciation, with opening written down value to be aligned with any accepted prior-year disallowance. Interest under section 234A required factual verification and recomputation if warranted. Case-Laws Income Tax Thu, 18 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277721