https://www.taxtmi.com/caselaws?id=464370 Transfer pricing analysis must rest on functional comparability and reliable contemporaneous data, so the foreign associated enterprises' suitability as the tested party required fresh examination under Rule 10D documentation principles. Corporate guarantees may be benchmarked as international transactions, and the guarantee fee adjustment was upheld in principle, but its quantification was remitted for recomputation. Outstanding trade receivables from associated enterprises can also be treated as a separate international transaction, and any notional interest must be recalculated after considering the commercial context, working capital impact, and the proper foreign currency interest benchmark. The matter was therefore remitted on all three issues for fresh consideration. en-us Mon, 13 Mar 2023 00:00:00 +0530 Fri, 24 Oct 2025 18:27:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464370 Transfer pricing analysis must rest on functional comparability and reliable contemporaneous data, so the foreign associated enterprises' suitability as the tested party required fresh examination under Rule 10D documentation principles. Corporate guarantees may be benchmarked as international transactions, and the guarantee fee adjustment was upheld in principle, but its quantification was remitted for recomputation. Outstanding trade receivables from associated enterprises can also be treated as a separate international transaction, and any notional interest must be recalculated after considering the commercial context, working capital impact, and the proper foreign currency interest benchmark. The matter was therefore remitted on all three issues for fresh consideration. Case-Laws Income Tax Mon, 13 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464370