https://www.taxtmi.com/caselaws?id=796254 Closely linked international transactions validly benchmarked under TNMM cannot be separately adjusted without evidence that the aggregation or arm's length outcome is inappropriate. Commission paid for export-order procurement and market-support services was treated as arm's length where associated enterprises rendered documented services, and commercial necessity could not be questioned. Exceptional pandemic-related advances and bad-debt write-offs were non-operating costs, supporting an arm's length sales margin. No separate notional-interest adjustment was warranted for trade receivables covered by the principal TNMM analysis and a uniform no-interest policy. The corporate-guarantee adjustment required verification of whether bank charges were fully recovered from associated enterprises. en-us Tue, 07 Jul 2026 00:00:00 +0530 Mon, 03 Aug 2026 08:20:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796254 Closely linked international transactions validly benchmarked under TNMM cannot be separately adjusted without evidence that the aggregation or arm's length outcome is inappropriate. Commission paid for export-order procurement and market-support services was treated as arm's length where associated enterprises rendered documented services, and commercial necessity could not be questioned. Exceptional pandemic-related advances and bad-debt write-offs were non-operating costs, supporting an arm's length sales margin. No separate notional-interest adjustment was warranted for trade receivables covered by the principal TNMM analysis and a uniform no-interest policy. The corporate-guarantee adjustment required verification of whether bank charges were fully recovered from associated enterprises. Case-Laws Income Tax Tue, 07 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796254