https://www.taxtmi.com/caselaws?id=468224 Export-linked incentives under the Merchandise Exports from India Scheme were treated as operating revenue because they arose from normal business exports and affected TNMM operating margin computation. Miscellaneous expenses were also regarded as operating items for both the assessee and comparables, as their routine business character governed their treatment. Where the primary international transactions were benchmarked under TNMM and the revised margin fell within the arm's length range, a separate notional interest adjustment on outstanding receivables was not warranted, particularly when interest was not charged uniformly from associated and non-associated enterprises. The transfer pricing additions were therefore deleted. en-us Fri, 07 Nov 2025 00:00:00 +0530 Thu, 23 Apr 2026 08:54:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468224 Export-linked incentives under the Merchandise Exports from India Scheme were treated as operating revenue because they arose from normal business exports and affected TNMM operating margin computation. Miscellaneous expenses were also regarded as operating items for both the assessee and comparables, as their routine business character governed their treatment. Where the primary international transactions were benchmarked under TNMM and the revised margin fell within the arm's length range, a separate notional interest adjustment on outstanding receivables was not warranted, particularly when interest was not charged uniformly from associated and non-associated enterprises. The transfer pricing additions were therefore deleted. Case-Laws Income Tax Fri, 07 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468224