https://www.taxtmi.com/caselaws?id=790233 Transfer pricing benchmarking requires reasoned consideration of material factual assertions and consistent prior-year treatment. Foreign exchange loss, customs duty adjustment, and price penetration adjustment were remitted for fresh examination because the lower authorities had not dealt with the supporting material in a reasoned manner. Liabilities written back were partly treated as operating income where they related to waived trade payables linked to earlier operating expenses, while the remaining items required verification. Capacity utilisation adjustment was recognised in principle, and benchmarking was directed to be recomputed on cash PLI, as that method was found to provide a reasonably accurate adjustment under Rule 10B. en-us Tue, 17 Mar 2026 00:00:00 +0530 Wed, 22 Apr 2026 08:47:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790233 Transfer pricing benchmarking requires reasoned consideration of material factual assertions and consistent prior-year treatment. Foreign exchange loss, customs duty adjustment, and price penetration adjustment were remitted for fresh examination because the lower authorities had not dealt with the supporting material in a reasoned manner. Liabilities written back were partly treated as operating income where they related to waived trade payables linked to earlier operating expenses, while the remaining items required verification. Capacity utilisation adjustment was recognised in principle, and benchmarking was directed to be recomputed on cash PLI, as that method was found to provide a reasonably accurate adjustment under Rule 10B. Case-Laws Income Tax Tue, 17 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790233