https://www.taxtmi.com/caselaws?id=786664 Selection of the tested party for transfer pricing must identify the least complex participant by functional analysis of assets, risks and functions; where one division performs routine procurement and sales with modest assets and another performs complex manufacturing, the routine division qualifies as the tested party and may be used to benchmark domestic purchases. Consistent functional matrices across years allow reliance on a subsequent year's Transfer Pricing Officer acceptance as corroborative evidence to support the same tested-party selection for an earlier year, sustaining rejection of revenue's challenge to the selection and adjustment. en-us Fri, 13 Feb 2026 00:00:00 +0530 Tue, 17 Feb 2026 07:29:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786664 Selection of the tested party for transfer pricing must identify the least complex participant by functional analysis of assets, risks and functions; where one division performs routine procurement and sales with modest assets and another performs complex manufacturing, the routine division qualifies as the tested party and may be used to benchmark domestic purchases. Consistent functional matrices across years allow reliance on a subsequent year's Transfer Pricing Officer acceptance as corroborative evidence to support the same tested-party selection for an earlier year, sustaining rejection of revenue's challenge to the selection and adjustment. Case-Laws Income Tax Fri, 13 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786664