https://www.taxtmi.com/caselaws?id=470106 Transfer-pricing comparability under Rule 10B should use consistent single-year data where exceptional market conditions, including pandemic disruption, materially affect the tested party's results; comparison with multi-year weighted margins from normal years may not be equitable. Sourcing support services involving supplier identification, procurement facilitation and customs clearance are examined under the benefit test and may not constitute shareholder activities where an independent enterprise would pay for them. Separate benchmarking depends on whether the transaction's costs, revenues and risks can be reliably identified. Income computation should also conform to assessment findings allowing research-related deductions, rather than retain disallowances arising from earlier processing. en-us Tue, 17 Mar 2026 00:00:00 +0530 Wed, 15 Jul 2026 18:59:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470106 Transfer-pricing comparability under Rule 10B should use consistent single-year data where exceptional market conditions, including pandemic disruption, materially affect the tested party's results; comparison with multi-year weighted margins from normal years may not be equitable. Sourcing support services involving supplier identification, procurement facilitation and customs clearance are examined under the benefit test and may not constitute shareholder activities where an independent enterprise would pay for them. Separate benchmarking depends on whether the transaction's costs, revenues and risks can be reliably identified. Income computation should also conform to assessment findings allowing research-related deductions, rather than retain disallowances arising from earlier processing. Case-Laws Income Tax Tue, 17 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470106