https://www.taxtmi.com/caselaws?id=797371 Under TNMM, material economic differences between a first-year tested party and established comparables require reasonably quantifiable adjustments. Underutilised capacity may be adjusted using average available capacity data from final comparables, and pre-commencement expenditure unrelated to benchmarked international transactions should be excluded from operating cost. Working-capital adjustment may be computed from publicly available opening and closing balances without unavailable intra-year or trade/non-trade data. Comparable companies are not persistently loss-making if profitable in one of the three relevant years. The applicable tolerance band must be applied after revised benchmarking, deleting any adjustment within that range. Abnormal packing cost remains operating cost unless shown unrecoverable. UPS is functionally part of a computer system for depreciation purposes. en-us Tue, 21 Jul 2026 00:00:00 +0530 Fri, 21 Aug 2026 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797371 Under TNMM, material economic differences between a first-year tested party and established comparables require reasonably quantifiable adjustments. Underutilised capacity may be adjusted using average available capacity data from final comparables, and pre-commencement expenditure unrelated to benchmarked international transactions should be excluded from operating cost. Working-capital adjustment may be computed from publicly available opening and closing balances without unavailable intra-year or trade/non-trade data. Comparable companies are not persistently loss-making if profitable in one of the three relevant years. The applicable tolerance band must be applied after revised benchmarking, deleting any adjustment within that range. Abnormal packing cost remains operating cost unless shown unrecoverable. UPS is functionally part of a computer system for depreciation purposes. Case-Laws Income Tax Tue, 21 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797371