https://www.taxtmi.com/caselaws?id=796945 TNMM requires primary focus on functional comparability. Reliable segmental data for indenting services may support use of that segment as a comparable for marketing-support commission despite the enterprise's predominant trading activity, where functions, assets and risks are similar. Foreign-currency loans to wholly owned associated enterprises may be benchmarked against LIBOR with an additional risk spread only if differential credit risk or other risk factors justify it. Delayed associated-enterprise receivables constitute an international transaction, but a separate interest adjustment should not duplicate the time-value impact already captured through an appropriate working-capital adjustment. Verification of working-capital-adjusted margins determines whether a separate receivables adjustment is required. en-us Fri, 17 Jul 2026 00:00:00 +0530 Thu, 13 Aug 2026 08:30:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796945 TNMM requires primary focus on functional comparability. Reliable segmental data for indenting services may support use of that segment as a comparable for marketing-support commission despite the enterprise's predominant trading activity, where functions, assets and risks are similar. Foreign-currency loans to wholly owned associated enterprises may be benchmarked against LIBOR with an additional risk spread only if differential credit risk or other risk factors justify it. Delayed associated-enterprise receivables constitute an international transaction, but a separate interest adjustment should not duplicate the time-value impact already captured through an appropriate working-capital adjustment. Verification of working-capital-adjusted margins determines whether a separate receivables adjustment is required. Case-Laws Income Tax Fri, 17 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796945