https://www.taxtmi.com/caselaws?id=794983 Transfer-pricing comparability in an extraordinary market year should account for pandemic-related operational disruption, reduced sales and fixed-cost under-absorption through a like-to-like comparison of the tested party and comparables for the same year. The notes state that Rules 10B(2) and 10B(3) require consideration of market conditions and reasonable adjustments for material differences. They also state that management-service charges supported by agreements, allocation details and benefit evidence should not be reduced to nil merely on commercial-expediency grounds. Where such services are interrelated with core operations and an aggregated TNMM analysis is accepted, separate benchmarking is not appropriate without independent 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 should account for pandemic-related operational disruption, reduced sales and fixed-cost under-absorption through a like-to-like comparison of the tested party and comparables for the same year. The notes state that Rules 10B(2) and 10B(3) require consideration of market conditions and reasonable adjustments for material differences. They also state that management-service charges supported by agreements, allocation details and benefit evidence should not be reduced to nil merely on commercial-expediency grounds. Where such services are interrelated with core operations and an aggregated TNMM analysis is accepted, separate benchmarking is not appropriate without independent analysis. Case-Laws Income Tax Thu, 04 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794983