https://www.taxtmi.com/caselaws?id=780106 In transfer pricing, operating margins must be computed by confining the analysis to international transactions alone, so domestic revenue and expenditure were excluded from the margin computation. The related party transaction filter was required to be applied consistently on an aggregate basis, and comparables failing that correctly computed filter or lacking functional comparability were excluded, while entities supported by a valid database search could be retained subject to verification. Interest on delayed receivables from associated enterprises was benchmarked at LIBOR plus 200 basis points, whereas interest on Indian-currency compulsorily convertible debentures had to be benchmarked with SBI Prime Lending Rate rather than SIBOR. The assessment was therefore recomputed on these transfer pricing issues. en-us Wed, 08 Oct 2025 00:00:00 +0530 Sat, 18 Oct 2025 09:08:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780106 In transfer pricing, operating margins must be computed by confining the analysis to international transactions alone, so domestic revenue and expenditure were excluded from the margin computation. The related party transaction filter was required to be applied consistently on an aggregate basis, and comparables failing that correctly computed filter or lacking functional comparability were excluded, while entities supported by a valid database search could be retained subject to verification. Interest on delayed receivables from associated enterprises was benchmarked at LIBOR plus 200 basis points, whereas interest on Indian-currency compulsorily convertible debentures had to be benchmarked with SBI Prime Lending Rate rather than SIBOR. The assessment was therefore recomputed on these transfer pricing issues. Case-Laws Income Tax Wed, 08 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780106