https://www.taxtmi.com/highlights?id=102167 Sales commission paid to an associated enterprise was supported by a written inter-company agreement and export-chain records, including purchase orders, supply instructions, invoices and shipping documents. The commission was linked to sales procured through the associated enterprise and became payable after third-party supply orders were received; the arm's length price was therefore not treated as nil. For delayed associated-enterprise receivables, the accepted TNMM operating margin and working-capital adjustment were considered to neutralise delayed realisation. As no differential credit benefit or real, determinable notional income was shown, a separate notional-interest adjustment was considered unwarranted. Both transfer-pricing adjustments were deleted. en-us Wed, 29 Jul 2026 09:27:51 +0530 Wed, 29 Jul 2026 09:27:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102167 Sales commission paid to an associated enterprise was supported by a written inter-company agreement and export-chain records, including purchase orders, supply instructions, invoices and shipping documents. The commission was linked to sales procured through the associated enterprise and became payable after third-party supply orders were received; the arm's length price was therefore not treated as nil. For delayed associated-enterprise receivables, the accepted TNMM operating margin and working-capital adjustment were considered to neutralise delayed realisation. As no differential credit benefit or real, determinable notional income was shown, a separate notional-interest adjustment was considered unwarranted. Both transfer-pricing adjustments were deleted. Highlights Income Tax Wed, 29 Jul 2026 09:27:51 +0530 https://www.taxtmi.com/highlights?id=102167