https://www.taxtmi.com/caselaws?id=466056 Transfer pricing review addressed selection of MAM and comparability, with TNMM applied as the MAM and no prohibition on examining functional comparability of selected entities, resulting in affirmation of the benchmarking carried out by the tax authorities. Comparable rejection was upheld where requisite financial statements lacked profit and loss details, resulting in exclusion of that entity. Economic or market-driven adjustments were held discretionary and unnecessary absent unique adverse conditions, resulting in denial of adjustment. Foreign exchange fluctuations were treated as part of operating costs and included for comparability, resulting in upholding their inclusion. Trade receivables were treated as a separate international transaction liable for benchmarking, but normal credit period exclusion for notional interest was directed, resulting in a partial allowance. en-us Thu, 16 Jan 2025 00:00:00 +0530 Wed, 21 Jan 2026 20:45:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466056 Transfer pricing review addressed selection of MAM and comparability, with TNMM applied as the MAM and no prohibition on examining functional comparability of selected entities, resulting in affirmation of the benchmarking carried out by the tax authorities. Comparable rejection was upheld where requisite financial statements lacked profit and loss details, resulting in exclusion of that entity. Economic or market-driven adjustments were held discretionary and unnecessary absent unique adverse conditions, resulting in denial of adjustment. Foreign exchange fluctuations were treated as part of operating costs and included for comparability, resulting in upholding their inclusion. Trade receivables were treated as a separate international transaction liable for benchmarking, but normal credit period exclusion for notional interest was directed, resulting in a partial allowance. Case-Laws Income Tax Thu, 16 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466056