https://www.taxtmi.com/caselaws?id=795593 Transfer-pricing guidance emphasises that domestic sales cannot serve as CUP for export transactions without strict comparability across markets, functions, risks and pricing factors; TNMM based on contribution margin was considered appropriate. Delayed associated-enterprise receivables are international transactions benchmarked at LIBOR plus 100 basis points after the applicable credit period, rather than domestic lending rates. The notes also address deletion of director-commission and additional-depreciation disallowances, treaty-rate treatment of dividend distribution tax pending binding judicial resolution, exclusion of unutilised Modvat/Cenvat credit from closing-stock additions, and fresh examination of exempt-income expenditure where own funds and actual exempt income are relevant. en-us Tue, 02 Jun 2026 00:00:00 +0530 Fri, 24 Jul 2026 08:36:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795593 Transfer-pricing guidance emphasises that domestic sales cannot serve as CUP for export transactions without strict comparability across markets, functions, risks and pricing factors; TNMM based on contribution margin was considered appropriate. Delayed associated-enterprise receivables are international transactions benchmarked at LIBOR plus 100 basis points after the applicable credit period, rather than domestic lending rates. The notes also address deletion of director-commission and additional-depreciation disallowances, treaty-rate treatment of dividend distribution tax pending binding judicial resolution, exclusion of unutilised Modvat/Cenvat credit from closing-stock additions, and fresh examination of exempt-income expenditure where own funds and actual exempt income are relevant. Case-Laws Income Tax Tue, 02 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795593