https://www.taxtmi.com/caselaws?id=797771 Comparable Uncontrolled Price (CUP) Method may benchmark exports to associated enterprises where independent purchases provide reliable comparables and material differences can be adjusted; unsubstantiated objections based on geography, volume or timing do not displace CUP. TNMM may be unreliable for a first-year producer without meaningful capacity-utilisation adjustments. Foreign-currency borrowings require currency-specific arm's length benchmarking that accounts for tenure, security, credit and market risks; a uniform LIBOR spread without comparables is insufficient. Delayed foreign-currency receivables constitute a separate international transaction, with interest benchmarked at LIBOR plus 200 basis points after a 60-day credit period rather than domestic deposit rates. Transfer-pricing relief applies to export sales and external commercial borrowings. en-us Wed, 19 Aug 2026 00:00:00 +0530 Thu, 27 Aug 2026 08:28:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797771 Comparable Uncontrolled Price (CUP) Method may benchmark exports to associated enterprises where independent purchases provide reliable comparables and material differences can be adjusted; unsubstantiated objections based on geography, volume or timing do not displace CUP. TNMM may be unreliable for a first-year producer without meaningful capacity-utilisation adjustments. Foreign-currency borrowings require currency-specific arm's length benchmarking that accounts for tenure, security, credit and market risks; a uniform LIBOR spread without comparables is insufficient. Delayed foreign-currency receivables constitute a separate international transaction, with interest benchmarked at LIBOR plus 200 basis points after a 60-day credit period rather than domestic deposit rates. Transfer-pricing relief applies to export sales and external commercial borrowings. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797771