https://www.taxtmi.com/caselaws?id=789192 Where transactions not covered by a Bilateral Advance Pricing Agreement are functionally indistinguishable from covered transactions and no separate benchmarking is undertaken, the agreed APA/BAPA margin may be adopted as a persuasive arm's length benchmark. The tribunal accepted that the non-covered associated enterprise transactions showed no material difference in functional, asset, and risk profile, and applied the same margin on the principle of consistency. The transfer pricing adjustment was therefore reduced by extending the agreed margin to the remaining international transactions. en-us Mon, 30 Mar 2026 00:00:00 +0530 Sat, 04 Apr 2026 08:53:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789192 Where transactions not covered by a Bilateral Advance Pricing Agreement are functionally indistinguishable from covered transactions and no separate benchmarking is undertaken, the agreed APA/BAPA margin may be adopted as a persuasive arm's length benchmark. The tribunal accepted that the non-covered associated enterprise transactions showed no material difference in functional, asset, and risk profile, and applied the same margin on the principle of consistency. The transfer pricing adjustment was therefore reduced by extending the agreed margin to the remaining international transactions. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789192