https://www.taxtmi.com/caselaws?id=798012 TNMM benchmarking requires comparables that match the tested party's functions and risk profile. For a routine rice trader, companies engaged in milling, processing or manufacturing introduce margins linked to different assets and risks and should be excluded; a predominantly trading company requires assessment using segmental data. Cash discounts linked to purchase costs and export-incentive proceeds from licence sales are operating items when they arise from normal business operations. Excluding such receipts can distort a like-to-like operating-margin comparison. The benchmark is recomputed using functionally comparable entities and those business-linked receipts as operating income. en-us Wed, 19 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798012 TNMM benchmarking requires comparables that match the tested party's functions and risk profile. For a routine rice trader, companies engaged in milling, processing or manufacturing introduce margins linked to different assets and risks and should be excluded; a predominantly trading company requires assessment using segmental data. Cash discounts linked to purchase costs and export-incentive proceeds from licence sales are operating items when they arise from normal business operations. Excluding such receipts can distort a like-to-like operating-margin comparison. The benchmark is recomputed using functionally comparable entities and those business-linked receipts as operating income. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798012