https://www.taxtmi.com/caselaws?id=468240 Transfer pricing adjustments require verifiable comparability data before any basic customs duty correction is allowed, and an unsupported claim will fail. Working capital differences are economically relevant under TNMM, so a reasonable adjustment may be granted where material differences exist. Notional interest on receivables should be assessed holistically, and benchmarking only receivables is inappropriate where substantial interest-free payables to the same associated enterprises exist. For external commercial borrowing, the loan's actual purpose must govern benchmarking; a borrowing for capital goods or facility expansion cannot be treated as a working capital loan without proper basis. en-us Wed, 06 Aug 2025 00:00:00 +0530 Wed, 22 Apr 2026 14:47:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468240 Transfer pricing adjustments require verifiable comparability data before any basic customs duty correction is allowed, and an unsupported claim will fail. Working capital differences are economically relevant under TNMM, so a reasonable adjustment may be granted where material differences exist. Notional interest on receivables should be assessed holistically, and benchmarking only receivables is inappropriate where substantial interest-free payables to the same associated enterprises exist. For external commercial borrowing, the loan's actual purpose must govern benchmarking; a borrowing for capital goods or facility expansion cannot be treated as a working capital loan without proper basis. Case-Laws Income Tax Wed, 06 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468240