https://www.taxtmi.com/caselaws?id=797672 Transfer-pricing benchmarking under the Resale Price Method permits an associated enterprise to be selected as the tested party where it is the less complex entity and reliable margins from comparable uncontrolled transactions are available. Merchant-trading transactions involving back-to-back USD purchases and sales, letters of credit, insignificant working-capital needs and limited inventory, credit, market and foreign-exchange risks supported that selection. A single material comparable invoice may be used under Rule 10B(1)(b). Manufacturing comparables with materially different functions, assets and risks were unsuitable, resulting in acceptance of the Resale Price Method analysis and no adjustment beyond the taxpayer's voluntary adjustment. en-us Fri, 19 Jun 2026 00:00:00 +0530 Wed, 26 Aug 2026 08:27:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797672 Transfer-pricing benchmarking under the Resale Price Method permits an associated enterprise to be selected as the tested party where it is the less complex entity and reliable margins from comparable uncontrolled transactions are available. Merchant-trading transactions involving back-to-back USD purchases and sales, letters of credit, insignificant working-capital needs and limited inventory, credit, market and foreign-exchange risks supported that selection. A single material comparable invoice may be used under Rule 10B(1)(b). Manufacturing comparables with materially different functions, assets and risks were unsuitable, resulting in acceptance of the Resale Price Method analysis and no adjustment beyond the taxpayer's voluntary adjustment. Case-Laws Income Tax Fri, 19 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797672