https://www.taxtmi.com/caselaws?id=471819 Limited-risk distributors performing routine promotion, invoicing, customer support and compliance functions, while holding no valuable intangibles and bearing limited operational risk, should be benchmarked under the Transactional Net Margin Method where it produces a reliable arm's-length result. Royalty agreements pricing content or technology rights not acquired or exploited by the distributor are not reliable comparables for the Other Method. Functional allocations require external comparability and a supportable cost-driver and risk-return basis. Income computation should conform to the correct section 143(1)(a) intimation where an assessment records a higher figure. en-us Fri, 17 Oct 2025 00:00:00 +0530 Sat, 19 Sep 2026 10:03:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471819 Limited-risk distributors performing routine promotion, invoicing, customer support and compliance functions, while holding no valuable intangibles and bearing limited operational risk, should be benchmarked under the Transactional Net Margin Method where it produces a reliable arm's-length result. Royalty agreements pricing content or technology rights not acquired or exploited by the distributor are not reliable comparables for the Other Method. Functional allocations require external comparability and a supportable cost-driver and risk-return basis. Income computation should conform to the correct section 143(1)(a) intimation where an assessment records a higher figure. Case-Laws Income Tax Fri, 17 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471819