https://www.taxtmi.com/caselaws?id=797582 Associated Enterprise status under section 92A requires the foundational test of direct or indirect participation in management, control or capital; the circumstances listed in section 92A(2), including commercial dependence or distributor exclusivity, do not independently establish that status. Internal CUP comparability does not require identical contractual terms. Contractual differences must be assessed for their material effect on price, and reasonably accurate, objectively verifiable adjustments must be considered under Rule 10B(3). Where CUP cannot be reliably applied after that assessment, the most appropriate method must be selected independently under section 92C and Rules 10B and 10C for royalty benchmarking. en-us Mon, 17 Aug 2026 00:00:00 +0530 Tue, 25 Aug 2026 08:34:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797582 Associated Enterprise status under section 92A requires the foundational test of direct or indirect participation in management, control or capital; the circumstances listed in section 92A(2), including commercial dependence or distributor exclusivity, do not independently establish that status. Internal CUP comparability does not require identical contractual terms. Contractual differences must be assessed for their material effect on price, and reasonably accurate, objectively verifiable adjustments must be considered under Rule 10B(3). Where CUP cannot be reliably applied after that assessment, the most appropriate method must be selected independently under section 92C and Rules 10B and 10C for royalty benchmarking. Case-Laws Income Tax Mon, 17 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797582