https://www.taxtmi.com/caselaws?id=797672 Resale Price Method permits reliance on one or more comparable uncontrolled transactions. Where the foreign associated enterprise is the less complex entity, its margins from trading similar goods with independent parties may provide valid comparables. A high-sea, back-to-back merchant-trading arrangement with secured USD purchases and sales, and without material inventory, market, collection, foreign-exchange or working-capital risks, differs functionally from manufacturing comparables. A time gap does not invalidate a comparable absent a material difference in functions, assets or risks. Benchmarking based on the foreign associated enterprise's comparable transactions was accepted, with no adjustment beyond that voluntarily offered. en-us Wed, 19 Aug 2026 00:00:00 +0530 Mon, 07 Sep 2026 14:51:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797672 Resale Price Method permits reliance on one or more comparable uncontrolled transactions. Where the foreign associated enterprise is the less complex entity, its margins from trading similar goods with independent parties may provide valid comparables. A high-sea, back-to-back merchant-trading arrangement with secured USD purchases and sales, and without material inventory, market, collection, foreign-exchange or working-capital risks, differs functionally from manufacturing comparables. A time gap does not invalidate a comparable absent a material difference in functions, assets or risks. Benchmarking based on the foreign associated enterprise's comparable transactions was accepted, with no adjustment beyond that voluntarily offered. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797672