https://www.taxtmi.com/caselaws?id=471298 Sale-of-goods arm's length price adjustment requires fresh determination where filed transfer-pricing documentation was not considered, because it is material to benchmarking and the taxpayer's functional profile; the adjustment was set aside for reconsideration. Notional interest on associated-enterprise trade receivables cannot be computed in isolation where interest-free trade payables coexist. Computation must account for both receivables and payables and their respective outstanding periods; the interest adjustment was set aside for recomputation. Both transfer-pricing matters require determination on a complete factual record. en-us Fri, 04 Apr 2025 00:00:00 +0530 Fri, 28 Aug 2026 20:38:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471298 Sale-of-goods arm's length price adjustment requires fresh determination where filed transfer-pricing documentation was not considered, because it is material to benchmarking and the taxpayer's functional profile; the adjustment was set aside for reconsideration. Notional interest on associated-enterprise trade receivables cannot be computed in isolation where interest-free trade payables coexist. Computation must account for both receivables and payables and their respective outstanding periods; the interest adjustment was set aside for recomputation. Both transfer-pricing matters require determination on a complete factual record. Case-Laws Income Tax Fri, 04 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471298