https://www.taxtmi.com/caselaws?id=794891 Aggregated benchmarking under the Transactional Net Margin Method (TNMM) treats interrelated international transactions as part of the tested segment. Where royalty and Global Accounts Manager charges are already included in the logistics segment's operating costs and assessed through the combined approach, separately benchmarking those same components may distort the arm's length analysis and result in duplicate adjustments. The note therefore identifies separate transfer pricing adjustments for those costs as impermissible once the combined TNMM approach is accepted. It also records that claims concerning TDS credit and errors in computing interest and fees require fresh verification by the assessing authority after providing the assessee an opportunity to be heard. en-us Fri, 29 May 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794891 Aggregated benchmarking under the Transactional Net Margin Method (TNMM) treats interrelated international transactions as part of the tested segment. Where royalty and Global Accounts Manager charges are already included in the logistics segment's operating costs and assessed through the combined approach, separately benchmarking those same components may distort the arm's length analysis and result in duplicate adjustments. The note therefore identifies separate transfer pricing adjustments for those costs as impermissible once the combined TNMM approach is accepted. It also records that claims concerning TDS credit and errors in computing interest and fees require fresh verification by the assessing authority after providing the assessee an opportunity to be heard. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794891