https://www.taxtmi.com/caselaws?id=800098 Transfer-pricing benchmarking requires separate evaluation of sub-contract and support-service transactions where separate agreements, functional profiles, risk allocation and audited segmental accounts show they are not closely linked. Support services rendered to an associated enterprise on a cost-plus, limited-risk basis differ from end-to-end sub-contract performance for third-party customers involving market and service-delivery risks; aggregation is therefore inappropriate. Notional interest on outstanding receivables is not sustainable where the entity is debt-free, has interest-free advances from its associated enterprise, holds net payables, and has not used borrowed funds to extend credit. en-us Fri, 18 Sep 2026 00:00:00 +0530 Thu, 01 Oct 2026 07:40:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800098 Transfer-pricing benchmarking requires separate evaluation of sub-contract and support-service transactions where separate agreements, functional profiles, risk allocation and audited segmental accounts show they are not closely linked. Support services rendered to an associated enterprise on a cost-plus, limited-risk basis differ from end-to-end sub-contract performance for third-party customers involving market and service-delivery risks; aggregation is therefore inappropriate. Notional interest on outstanding receivables is not sustainable where the entity is debt-free, has interest-free advances from its associated enterprise, holds net payables, and has not used borrowed funds to extend credit. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800098