https://www.taxtmi.com/caselaws?id=790965 Under TNMM, comparables must be tested for functional similarity, assets employed, risks assumed and material differences, including working capital impact, with exclusion of functionally dissimilar entities and use of an aggregate RPT filter where appropriate. Delayed receivables from associated enterprises may be a separate international transaction, but the adjustment must be aligned with the final working capital analysis. Reimbursement of expenses cannot carry an ad hoc mark-up without a proper statutory or factual basis. Questions of notional interest on a loan require fresh examination where recovery, impairment and accrual are uncertain, and tax credit for merged entities depends on verification of credits and corresponding income in light of amalgamation from the appointed date. en-us Mon, 23 Feb 2026 00:00:00 +0530 Mon, 04 May 2026 07:57:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790965 Under TNMM, comparables must be tested for functional similarity, assets employed, risks assumed and material differences, including working capital impact, with exclusion of functionally dissimilar entities and use of an aggregate RPT filter where appropriate. Delayed receivables from associated enterprises may be a separate international transaction, but the adjustment must be aligned with the final working capital analysis. Reimbursement of expenses cannot carry an ad hoc mark-up without a proper statutory or factual basis. Questions of notional interest on a loan require fresh examination where recovery, impairment and accrual are uncertain, and tax credit for merged entities depends on verification of credits and corresponding income in light of amalgamation from the appointed date. Case-Laws Income Tax Mon, 23 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790965