https://www.taxtmi.com/caselaws?id=795593 Transfer-pricing benchmarking of exports of water-based paints required strict CUP comparability; domestic sales could not serve as comparables without adjustments for different markets, functions, risks and pricing conditions, and TNMM using contribution margin was accepted, deleting the adjustment. Delayed associated-enterprise receivables were treated as an international transaction and remitted for recomputation at LIBOR plus 100 basis points after the applicable credit period. Commission disallowance was deleted, and the remaining additional depreciation for machinery used below 180 days was allowed in the succeeding year. DDT treaty limitation and exempt-income expenditure disallowance require fresh determination. Unutilised Modvat/Cenvat credit could not be added to closing stock on the stated facts. 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 benchmarking of exports of water-based paints required strict CUP comparability; domestic sales could not serve as comparables without adjustments for different markets, functions, risks and pricing conditions, and TNMM using contribution margin was accepted, deleting the adjustment. Delayed associated-enterprise receivables were treated as an international transaction and remitted for recomputation at LIBOR plus 100 basis points after the applicable credit period. Commission disallowance was deleted, and the remaining additional depreciation for machinery used below 180 days was allowed in the succeeding year. DDT treaty limitation and exempt-income expenditure disallowance require fresh determination. Unutilised Modvat/Cenvat credit could not be added to closing stock on the stated facts. Case-Laws Income Tax Tue, 02 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795593