https://www.taxtmi.com/caselaws?id=787976 Comparable selection under TNMM must be tested on functional similarity and commercially relevant comparability factors; excluded comparables found functionally similar were directed to be included, while objections to one TPO-selected comparable were remanded for limited verification of related-party transactions and outsourcing expenses. A guarantee commission adjustment was not sustained where the arrangement was back-to-back, the assessee performed only a limited execution role, and it did not bear the underlying credit or performance risk. Disallowance of payments to VISA and MasterCard was deleted because withholding tax liability had to be determined under the law prevailing at the time of payment. A corresponding reduction was allowed to prevent double taxation of income already taxed in an earlier year. en-us Thu, 12 Feb 2026 00:00:00 +0530 Fri, 13 Mar 2026 10:20:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787976 Comparable selection under TNMM must be tested on functional similarity and commercially relevant comparability factors; excluded comparables found functionally similar were directed to be included, while objections to one TPO-selected comparable were remanded for limited verification of related-party transactions and outsourcing expenses. A guarantee commission adjustment was not sustained where the arrangement was back-to-back, the assessee performed only a limited execution role, and it did not bear the underlying credit or performance risk. Disallowance of payments to VISA and MasterCard was deleted because withholding tax liability had to be determined under the law prevailing at the time of payment. A corresponding reduction was allowed to prevent double taxation of income already taxed in an earlier year. Case-Laws Income Tax Thu, 12 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787976