https://www.taxtmi.com/caselaws?id=796870 Transfer-pricing benchmarking for imported finished SIM cards must reflect the assessee's actual reseller/distributor profile. Electrical embossing of customer logos or designs does not convert the distributor into a manufacturer, service provider, or risk-bearing group entrepreneur. Service, system-integration, software and manufacturing companies with research and development activities, intangibles, plants, technology or royalty arrangements are functionally unsuitable comparables and must be excluded. Comparable companies with an unchanged business profile and available annual reports should be retained. Where comparables are rejected solely for unavailable database data, financial information should be obtained through internal or statutory information-gathering mechanisms before a reasoned exclusion. The arm's length price requires fresh computation using functionally comparable distributors. en-us Thu, 11 Jun 2026 00:00:00 +0530 Wed, 12 Aug 2026 08:19:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796870 Transfer-pricing benchmarking for imported finished SIM cards must reflect the assessee's actual reseller/distributor profile. Electrical embossing of customer logos or designs does not convert the distributor into a manufacturer, service provider, or risk-bearing group entrepreneur. Service, system-integration, software and manufacturing companies with research and development activities, intangibles, plants, technology or royalty arrangements are functionally unsuitable comparables and must be excluded. Comparable companies with an unchanged business profile and available annual reports should be retained. Where comparables are rejected solely for unavailable database data, financial information should be obtained through internal or statutory information-gathering mechanisms before a reasoned exclusion. The arm's length price requires fresh computation using functionally comparable distributors. Case-Laws Income Tax Thu, 11 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796870