https://www.taxtmi.com/highlights?id=103554 Transfer-pricing benchmarking of back-office support services requires comparables with similar functions and risk profiles; specialised engineering, knowledge-process, outsourced, geographically distinct businesses and entities affected by extraordinary events were excluded, while one comparable was retained, requiring recomputation of the adjustment. A low-risk captive service provider is entitled to a working-capital adjustment on furnishing supporting computations. Separate notional interest on associated-enterprise receivables cannot be charged where receivables are already reflected in working-capital adjustment and service pricing, as this duplicates the adjustment. Associated-enterprise cost allocations incurred without mark-up cann..... en-us Wed, 09 Sep 2026 08:20:28 +0530 Wed, 09 Sep 2026 08:20:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103554 Transfer-pricing benchmarking of back-office support services requires comparables with similar functions and risk profiles; specialised engineering, knowledge-process, outsourced, geographically distinct businesses and entities affected by extraordinary events were excluded, while one comparable was retained, requiring recomputation of the adjustment. A low-risk captive service provider is entitled to a working-capital adjustment on furnishing supporting computations. Separate notional interest on associated-enterprise receivables cannot be charged where receivables are already reflected in working-capital adjustment and service pricing, as this duplicates the adjustment. Associated-enterprise cost allocations incurred without mark-up cann..... Highlights Income Tax Wed, 09 Sep 2026 08:20:28 +0530 https://www.taxtmi.com/highlights?id=103554