https://www.taxtmi.com/caselaws?id=790964 When TNMM is accepted as the most appropriate method, outstanding receivables are treated as embedded in the net margin and no separate notional interest adjustment is warranted if working capital effects are already considered. LIBOR plus 200 basis points was accepted as the arm's length rate for ECB interest. Lump-sum leasehold charges were treated as revenue expenditure allowable proportionately over the lease term, making the disallowance unsustainable. Royalty, however, should not be isolated for separate benchmarking when it forms part of aggregated transactions tested under TNMM; the matter was nevertheless restored for fresh adjudication because the operating cost adopted by the TPO did not reconcile with the books. en-us Wed, 18 Feb 2026 00:00:00 +0530 Mon, 04 May 2026 07:57:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790964 When TNMM is accepted as the most appropriate method, outstanding receivables are treated as embedded in the net margin and no separate notional interest adjustment is warranted if working capital effects are already considered. LIBOR plus 200 basis points was accepted as the arm's length rate for ECB interest. Lump-sum leasehold charges were treated as revenue expenditure allowable proportionately over the lease term, making the disallowance unsustainable. Royalty, however, should not be isolated for separate benchmarking when it forms part of aggregated transactions tested under TNMM; the matter was nevertheless restored for fresh adjudication because the operating cost adopted by the TPO did not reconcile with the books. Case-Laws Income Tax Wed, 18 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790964