https://www.taxtmi.com/caselaws?id=468219 Comparability adjustment under TNMM required customs duty on non-cenvatable imports and working capital differences to be factored into the margin analysis; both adjustments were allowed and recomputation was directed. Miscellaneous expenses were treated as operating expenses because their business character, not their label, governed comparability, and margins were to be recalculated accordingly. Royalty and technical fee payments closely linked to manufacturing activity were required to be aggregated with the tested transaction under TNMM; separate standalone benchmarking and disallowance were not justified, and those additions were set aside. en-us Fri, 30 May 2025 00:00:00 +0530 Wed, 22 Apr 2026 11:25:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468219 Comparability adjustment under TNMM required customs duty on non-cenvatable imports and working capital differences to be factored into the margin analysis; both adjustments were allowed and recomputation was directed. Miscellaneous expenses were treated as operating expenses because their business character, not their label, governed comparability, and margins were to be recalculated accordingly. Royalty and technical fee payments closely linked to manufacturing activity were required to be aggregated with the tested transaction under TNMM; separate standalone benchmarking and disallowance were not justified, and those additions were set aside. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468219