https://www.taxtmi.com/caselaws?id=796893 Audited accounts of a foreign company undertaking a qualifying turnkey power project cannot be rejected merely because they show losses, work-in-progress, revenue-recognition issues or freight-cost variations, unless material defects are established. A satisfactorily explained loss, including one arising from increased ocean-freight costs, does not justify presumptive profit computation. For transfer pricing, a third-party contract price may constitute a reliable internal Comparable Uncontrolled Price where the Indian project office executes the contract, bears the relevant risks and rewards, and receives the full contract revenue. In those circumstances, the internal CUP method is preferable to TNMM, and no TNMM-based adjustment is warranted. en-us Mon, 03 Aug 2026 00:00:00 +0530 Wed, 12 Aug 2026 08:20:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796893 Audited accounts of a foreign company undertaking a qualifying turnkey power project cannot be rejected merely because they show losses, work-in-progress, revenue-recognition issues or freight-cost variations, unless material defects are established. A satisfactorily explained loss, including one arising from increased ocean-freight costs, does not justify presumptive profit computation. For transfer pricing, a third-party contract price may constitute a reliable internal Comparable Uncontrolled Price where the Indian project office executes the contract, bears the relevant risks and rewards, and receives the full contract revenue. In those circumstances, the internal CUP method is preferable to TNMM, and no TNMM-based adjustment is warranted. Case-Laws Income Tax Mon, 03 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796893