https://www.taxtmi.com/caselaws?id=470276 An Advance Pricing Agreement operating-profit-to-operating-cost margin may serve as a reliable arm's length benchmark for an assessment year outside its formal coverage where the tested party, business activities, functional profile and nature of international transactions remain unchanged. The notes state that the APA accepted the taxpayer as the tested party and prescribed a 4.5% margin for later years. Applying that margin to the relevant year was considered appropriate because the underlying facts were materially identical, supporting determination of the arm's length profit margin on the APA basis. en-us Tue, 08 Jul 2025 00:00:00 +0530 Tue, 21 Jul 2026 19:10:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470276 An Advance Pricing Agreement operating-profit-to-operating-cost margin may serve as a reliable arm's length benchmark for an assessment year outside its formal coverage where the tested party, business activities, functional profile and nature of international transactions remain unchanged. The notes state that the APA accepted the taxpayer as the tested party and prescribed a 4.5% margin for later years. Applying that margin to the relevant year was considered appropriate because the underlying facts were materially identical, supporting determination of the arm's length profit margin on the APA basis. Case-Laws Income Tax Tue, 08 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470276