https://www.taxtmi.com/caselaws?id=471411 Transfer-pricing comparability must reflect prevailing market conditions and material differences affecting profitability. COVID-related conditions may make benchmarking a tested party's single-year profit level indicator against comparables' weighted average margins for multiple years inappropriate; contemporaneous single-year data should then be used. Proposed comparables require fresh evaluation where submissions and supporting material have not been properly considered. Intra-group technical, operational and consultancy services should not be assigned a nil arm's length price without properly examining agreements, invoices, email extracts and other evidence of service receipt. The transfer-pricing study should be redone after considering the taxpayer's evidence and submissions. en-us Fri, 05 Dec 2025 00:00:00 +0530 Tue, 01 Sep 2026 19:02:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471411 Transfer-pricing comparability must reflect prevailing market conditions and material differences affecting profitability. COVID-related conditions may make benchmarking a tested party's single-year profit level indicator against comparables' weighted average margins for multiple years inappropriate; contemporaneous single-year data should then be used. Proposed comparables require fresh evaluation where submissions and supporting material have not been properly considered. Intra-group technical, operational and consultancy services should not be assigned a nil arm's length price without properly examining agreements, invoices, email extracts and other evidence of service receipt. The transfer-pricing study should be redone after considering the taxpayer's evidence and submissions. Case-Laws Income Tax Fri, 05 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471411