https://www.taxtmi.com/caselaws?id=798815 Under the transactional net margin method, comparability depends on functions performed, assets employed and risks assumed; a turnover threshold alone cannot exclude a comparable without showing a material effect or considering reasonably accurate adjustments. Arm's-length adjustments are confined to international transactions with associated enterprises. Abnormal goodwill amortisation and non-associated-enterprise bad debts and legal expenses are excluded from operating computation, while import-duty adjustment is admissible; capacity-utilisation and working-capital claims require verification. Warranty, replacement costs and written-off bad debts are deductible on consistent facts. Reversal and write-back claims require reconciliation with earlier tax treatment, while doubtful advances may be claimed at the appellate stage. Business-right acquisition expenditure is revenue in nature despite possible enduring benefit, and capitalised software qualifies for 60% depreciation. en-us Wed, 09 Sep 2026 00:00:00 +0530 Sat, 12 Sep 2026 08:41:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798815 Under the transactional net margin method, comparability depends on functions performed, assets employed and risks assumed; a turnover threshold alone cannot exclude a comparable without showing a material effect or considering reasonably accurate adjustments. Arm's-length adjustments are confined to international transactions with associated enterprises. Abnormal goodwill amortisation and non-associated-enterprise bad debts and legal expenses are excluded from operating computation, while import-duty adjustment is admissible; capacity-utilisation and working-capital claims require verification. Warranty, replacement costs and written-off bad debts are deductible on consistent facts. Reversal and write-back claims require reconciliation with earlier tax treatment, while doubtful advances may be claimed at the appellate stage. Business-right acquisition expenditure is revenue in nature despite possible enduring benefit, and capitalised software qualifies for 60% depreciation. Case-Laws Income Tax Wed, 09 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798815