https://www.taxtmi.com/caselaws?id=799956 Explanation 7 to Section 271(1)(c) requires assessment of whether the arm's length price was determined under Section 92C and whether the taxpayer acted in good faith and with due diligence. Use of the transactional net margin method, coupled with disclosure of filters, comparables and operating-margin computations in a transfer-pricing study, supports compliance where no finding establishes a departure from the statutory framework or lack of good faith. Methodological differences over the profit-level indicator or treatment of operating items, without false or inaccurate particulars, do not sustain a transfer-pricing penalty. en-us Fri, 18 Sep 2026 00:00:00 +0530 Tue, 29 Sep 2026 08:34:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799956 Explanation 7 to Section 271(1)(c) requires assessment of whether the arm's length price was determined under Section 92C and whether the taxpayer acted in good faith and with due diligence. Use of the transactional net margin method, coupled with disclosure of filters, comparables and operating-margin computations in a transfer-pricing study, supports compliance where no finding establishes a departure from the statutory framework or lack of good faith. Methodological differences over the profit-level indicator or treatment of operating items, without false or inaccurate particulars, do not sustain a transfer-pricing penalty. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799956