https://www.taxtmi.com/caselaws?id=798673 Chapter X arm's-length adjustments are confined to international transactions with associated enterprises and cannot increase profit from independent-party dealings. Operating margins must reflect DRP-directed exclusions of warranty provision, bad debts written off, and marketing expenditure solely attributable to non-associated-enterprise sales. Business-related liability or provision write-backs and export incentives constitute operating revenue, without deducting separately disclosed other operating income from total revenue. Functional comparability depends on products and business activities. Where a working-capital adjustment under TNMM accounts for delayed associated-enterprise receivables, a separate notional-interest adjustment would duplicate the effect. Brought-forward unabsorbed depreciation cannot be set off against income from other sources. en-us Thu, 27 Aug 2026 00:00:00 +0530 Thu, 10 Sep 2026 08:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798673 Chapter X arm's-length adjustments are confined to international transactions with associated enterprises and cannot increase profit from independent-party dealings. Operating margins must reflect DRP-directed exclusions of warranty provision, bad debts written off, and marketing expenditure solely attributable to non-associated-enterprise sales. Business-related liability or provision write-backs and export incentives constitute operating revenue, without deducting separately disclosed other operating income from total revenue. Functional comparability depends on products and business activities. Where a working-capital adjustment under TNMM accounts for delayed associated-enterprise receivables, a separate notional-interest adjustment would duplicate the effect. Brought-forward unabsorbed depreciation cannot be set off against income from other sources. Case-Laws Income Tax Thu, 27 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798673