https://www.taxtmi.com/highlights?id=103084 High-sea merchant trading conducted through back-to-back USD sales, supported by letters of credit, may justify selecting the foreign associated enterprise as the tested party under the Resale Price Method where the Indian entity bears no significant inventory, collection, market or foreign-exchange risk and has minimal working-capital needs. The associated enterprise's trading margins with unrelated parties can serve as comparable uncontrolled transactions. Steel manufacturers are not functionally comparable to pure merchant traders because their functions, assets and risks materially differ. Currency conversion does not materially affect the analysis where both purchase and sale transactions are denominated in USD. en-us Wed, 26 Aug 2026 08:27:49 +0530 Wed, 26 Aug 2026 08:27:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103084 High-sea merchant trading conducted through back-to-back USD sales, supported by letters of credit, may justify selecting the foreign associated enterprise as the tested party under the Resale Price Method where the Indian entity bears no significant inventory, collection, market or foreign-exchange risk and has minimal working-capital needs. The associated enterprise's trading margins with unrelated parties can serve as comparable uncontrolled transactions. Steel manufacturers are not functionally comparable to pure merchant traders because their functions, assets and risks materially differ. Currency conversion does not materially affect the analysis where both purchase and sale transactions are denominated in USD. Highlights Income Tax Wed, 26 Aug 2026 08:27:49 +0530 https://www.taxtmi.com/highlights?id=103084