https://www.taxtmi.com/caselaws?id=798415 Transfer-pricing analysis treats enterprises as associated where an overseas entity's business is wholly dependent on regulatory affairs and compliance processes performed by the Indian entity, engaging section 92A(2)(g). The Indian entity remains the tested party where foreign comparable data cannot be readily accessed or verified. Regulatory affairs services cannot be re-characterised as knowledge process outsourcing unless they fall within Rule 10TA(g)'s exhaustive definition. Comparables performing materially different functions fail functional, asset and risk and comparability analysis; the arm's length price requires fresh benchmarking against functionally comparable entities after an opportunity to furnish relevant material. en-us Fri, 07 Aug 2026 00:00:00 +0530 Mon, 07 Sep 2026 08:48:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798415 Transfer-pricing analysis treats enterprises as associated where an overseas entity's business is wholly dependent on regulatory affairs and compliance processes performed by the Indian entity, engaging section 92A(2)(g). The Indian entity remains the tested party where foreign comparable data cannot be readily accessed or verified. Regulatory affairs services cannot be re-characterised as knowledge process outsourcing unless they fall within Rule 10TA(g)'s exhaustive definition. Comparables performing materially different functions fail functional, asset and risk and comparability analysis; the arm's length price requires fresh benchmarking against functionally comparable entities after an opportunity to furnish relevant material. Case-Laws Income Tax Fri, 07 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798415