https://www.taxtmi.com/caselaws?id=798578 Transfer-pricing adjustments under Chapter X are confined to income arising from international transactions with associated enterprises and cannot increase profits from independent-party dealings. Manufacturing-segment benchmarking therefore requires recomputation after limiting any adjustment to associated-enterprise transactions and revising the comparable set. Businesses engaged in materially different consumer, personal-care, fast-food or diversified food activities, particularly without relevant segmental data, are not functionally comparable to a ready-to-cook instant-noodle manufacturer; a convenience-packaged food and instant-mixes manufacturer remains comparable. AMP expenditure cannot be separately benchmarked using the Bright Line Test, which lacks statutory mandate, absent evidence of an arrangement or concerted action benefiting associated enterprises. The AMP adjustment is deleted. en-us Mon, 31 Aug 2026 00:00:00 +0530 Wed, 09 Sep 2026 08:20:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798578 Transfer-pricing adjustments under Chapter X are confined to income arising from international transactions with associated enterprises and cannot increase profits from independent-party dealings. Manufacturing-segment benchmarking therefore requires recomputation after limiting any adjustment to associated-enterprise transactions and revising the comparable set. Businesses engaged in materially different consumer, personal-care, fast-food or diversified food activities, particularly without relevant segmental data, are not functionally comparable to a ready-to-cook instant-noodle manufacturer; a convenience-packaged food and instant-mixes manufacturer remains comparable. AMP expenditure cannot be separately benchmarked using the Bright Line Test, which lacks statutory mandate, absent evidence of an arrangement or concerted action benefiting associated enterprises. The AMP adjustment is deleted. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798578