https://www.taxtmi.com/caselaws?id=797218 Transfer-pricing benchmarking must select the most appropriate method through a functional, asset and risk analysis. The Transactional Net Margin Method is appropriate where an importer performs package configuration, integration, installation, software activation, training, warranty, maintenance and technical support, rather than acting as a routine reseller. The Resale Price Method becomes unreliable when the reseller adds substantial value or transforms the goods, particularly where no defect is shown in the operating-margin analysis. Comparable companies require verification where their related party transactions may exceed the applicable filter. Claimed duplicate taxation of income already offered in the return also requires verification before retention of any addition. en-us Tue, 14 Jul 2026 00:00:00 +0530 Wed, 19 Aug 2026 08:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797218 Transfer-pricing benchmarking must select the most appropriate method through a functional, asset and risk analysis. The Transactional Net Margin Method is appropriate where an importer performs package configuration, integration, installation, software activation, training, warranty, maintenance and technical support, rather than acting as a routine reseller. The Resale Price Method becomes unreliable when the reseller adds substantial value or transforms the goods, particularly where no defect is shown in the operating-margin analysis. Comparable companies require verification where their related party transactions may exceed the applicable filter. Claimed duplicate taxation of income already offered in the return also requires verification before retention of any addition. Case-Laws Income Tax Tue, 14 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797218