https://www.taxtmi.com/caselaws?id=799309 Spare-replacement activities conducted without ownership of the parts, control over resale prices, or customer selection are characterised as service-provider functions for transfer-pricing purposes. The functional, assets and risks profile supports benchmarking under the Transactional Net Margin Method where the entity merely holds and delivers replacement parts to customers of its associated enterprise under that enterprise's directions. The Resale Price Method is not appropriate for such custodial service activity, as the entity does not undertake trading functions or assume the corresponding risks. en-us Tue, 08 Sep 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799309 Spare-replacement activities conducted without ownership of the parts, control over resale prices, or customer selection are characterised as service-provider functions for transfer-pricing purposes. The functional, assets and risks profile supports benchmarking under the Transactional Net Margin Method where the entity merely holds and delivers replacement parts to customers of its associated enterprise under that enterprise's directions. The Resale Price Method is not appropriate for such custodial service activity, as the entity does not undertake trading functions or assume the corresponding risks. Case-Laws Income Tax Tue, 08 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799309