https://www.taxtmi.com/caselaws?id=794983 Transfer-pricing comparability in an extraordinary market year must account for material differences in market conditions under Rules 10B(2) and 10B(3). Where pandemic-related disruption affects the tested party's single-year results, comparable companies' margins should be drawn from the same year to achieve a like-to-like comparison. Management-service charges supported by agreements, allocation records, correspondence, reports and need-benefit evidence cannot be reduced to nil merely by questioning commercial expediency. Where such services are interlinked with core business operations and an aggregated TNMM analysis has been accepted, separate benchmarking is not appropriate without independent arm's-length analysis. en-us Thu, 04 Jun 2026 00:00:00 +0530 Wed, 15 Jul 2026 08:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794983 Transfer-pricing comparability in an extraordinary market year must account for material differences in market conditions under Rules 10B(2) and 10B(3). Where pandemic-related disruption affects the tested party's single-year results, comparable companies' margins should be drawn from the same year to achieve a like-to-like comparison. Management-service charges supported by agreements, allocation records, correspondence, reports and need-benefit evidence cannot be reduced to nil merely by questioning commercial expediency. Where such services are interlinked with core business operations and an aggregated TNMM analysis has been accepted, separate benchmarking is not appropriate without independent arm's-length analysis. Case-Laws Income Tax Thu, 04 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794983