https://www.taxtmi.com/caselaws?id=796871 Transfer-pricing benchmarking of barite exports under the Transactional Net Margin Method requires functionally comparable trading entities and reliable operating-margin data. A company cannot be treated as persistently loss-making if it earned profit in one of the three relevant financial years, making Ashok Alcochem Ltd. eligible for inclusion. Entities predominantly engaged in processing or manufacturing, or lacking segmental information to isolate trading activity, are unsuitable comparables; HD Micrones Ltd., Shivom Minerals Ltd., Gimpex Pvt. Ltd. and Naga Ltd. are therefore excluded. The remaining comparable margins require verification against annual reports before recomputing the arm's length price. en-us Thu, 02 Jul 2026 00:00:00 +0530 Wed, 12 Aug 2026 08:19:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796871 Transfer-pricing benchmarking of barite exports under the Transactional Net Margin Method requires functionally comparable trading entities and reliable operating-margin data. A company cannot be treated as persistently loss-making if it earned profit in one of the three relevant financial years, making Ashok Alcochem Ltd. eligible for inclusion. Entities predominantly engaged in processing or manufacturing, or lacking segmental information to isolate trading activity, are unsuitable comparables; HD Micrones Ltd., Shivom Minerals Ltd., Gimpex Pvt. Ltd. and Naga Ltd. are therefore excluded. The remaining comparable margins require verification against annual reports before recomputing the arm's length price. Case-Laws Income Tax Thu, 02 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796871