https://www.taxtmi.com/caselaws?id=797681 AMP expenditure included in operating costs for interconnected international transactions benchmarked under TNMM cannot be separately subjected to an arm's-length adjustment where accepted net margins already absorb that cost; separate benchmarking without proper segregation would distort the selected method, and the Bright Line Test does not support a protective adjustment. A separate interest adjustment on outstanding receivables requires verification of whether working-capital adjustments already reflected the impact, to prevent duplication. A mismatch between returned income and Form 26AS receipts requires factual examination where receipts are claimed to belong to associated enterprises, including evidence relating to their Indian assessment and mutual agreement procedure. en-us Wed, 19 Aug 2026 00:00:00 +0530 Wed, 26 Aug 2026 08:27:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797681 AMP expenditure included in operating costs for interconnected international transactions benchmarked under TNMM cannot be separately subjected to an arm's-length adjustment where accepted net margins already absorb that cost; separate benchmarking without proper segregation would distort the selected method, and the Bright Line Test does not support a protective adjustment. A separate interest adjustment on outstanding receivables requires verification of whether working-capital adjustments already reflected the impact, to prevent duplication. A mismatch between returned income and Form 26AS receipts requires factual examination where receipts are claimed to belong to associated enterprises, including evidence relating to their Indian assessment and mutual agreement procedure. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797681