https://www.taxtmi.com/caselaws?id=470372 Club-membership fees for directors, managerial personnel and senior employees are deductible business expenditure where memberships facilitate interaction with customers and stakeholders in the course of business. For transfer-pricing benchmarking under the Transactional Net Margin Method, audited segmental accounts should be used where manufacturing and trading operations have distinct functions, assets and risks; the absence of segment data in published financial statements does not discredit available audited allocation details. Entities producing materially different ink products through different manufacturing processes are not functionally comparable merely because they operate in the broader ink industry. The transfer-pricing analysis should therefore use segmental results and exclude such dissimilar comparables. en-us Wed, 19 Mar 2025 00:00:00 +0530 Fri, 24 Jul 2026 21:47:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470372 Club-membership fees for directors, managerial personnel and senior employees are deductible business expenditure where memberships facilitate interaction with customers and stakeholders in the course of business. For transfer-pricing benchmarking under the Transactional Net Margin Method, audited segmental accounts should be used where manufacturing and trading operations have distinct functions, assets and risks; the absence of segment data in published financial statements does not discredit available audited allocation details. Entities producing materially different ink products through different manufacturing processes are not functionally comparable merely because they operate in the broader ink industry. The transfer-pricing analysis should therefore use segmental results and exclude such dissimilar comparables. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470372