https://www.taxtmi.com/caselaws?id=471264 Functional comparability under the Transactional Net Margin Method requires similarity in functions, products and economic circumstances; a government-supported copper producer is unsuitable for comparison with a steel-wire and rod manufacturer. Profit level indicator margins should be recomputed from annual-report figures. Interest on a subordinated loan to a Thai associated enterprise is prescribed at 9%, while corporate guarantee commission is benchmarked at 0.5%. For captive power, market value for the Section 80-IA deduction is the electricity board's tariff charged to industrial consumers, not its purchase price. Further disallowances of miscellaneous and foreign travel expenses are impermissible where prior disallowances already exceed the proposed adjustments, as they create double disallowance. en-us Thu, 12 Jun 2025 00:00:00 +0530 Wed, 26 Aug 2026 21:12:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471264 Functional comparability under the Transactional Net Margin Method requires similarity in functions, products and economic circumstances; a government-supported copper producer is unsuitable for comparison with a steel-wire and rod manufacturer. Profit level indicator margins should be recomputed from annual-report figures. Interest on a subordinated loan to a Thai associated enterprise is prescribed at 9%, while corporate guarantee commission is benchmarked at 0.5%. For captive power, market value for the Section 80-IA deduction is the electricity board's tariff charged to industrial consumers, not its purchase price. Further disallowances of miscellaneous and foreign travel expenses are impermissible where prior disallowances already exceed the proposed adjustments, as they create double disallowance. Case-Laws Income Tax Thu, 12 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471264