https://www.taxtmi.com/caselaws?id=796947 Audited segmental data should govern functional comparability in transfer-pricing analysis where it separately identifies a comparable's trading results; entity-level trading-income filters should not displace those segmental results. A company engaged exclusively in trading may satisfy the trading-income filter where its financial data supports that characterisation. Delayed receivables from associated enterprises may constitute a separate international transaction, but no independent notional-interest adjustment should arise if the working capital adjustment already captures the receivables differential against comparables. The arm's length price should accordingly be recomputed using the identified trading comparables, without duplicating the receivables adjustment. en-us Fri, 24 Jul 2026 00:00:00 +0530 Thu, 13 Aug 2026 08:30:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796947 Audited segmental data should govern functional comparability in transfer-pricing analysis where it separately identifies a comparable's trading results; entity-level trading-income filters should not displace those segmental results. A company engaged exclusively in trading may satisfy the trading-income filter where its financial data supports that characterisation. Delayed receivables from associated enterprises may constitute a separate international transaction, but no independent notional-interest adjustment should arise if the working capital adjustment already captures the receivables differential against comparables. The arm's length price should accordingly be recomputed using the identified trading comparables, without duplicating the receivables adjustment. Case-Laws Income Tax Fri, 24 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796947