https://www.taxtmi.com/caselaws?id=800397 Comparable Uncontrolled Price Method benchmarking requires materially comparable transactions: processed, sorted, packed and delivered export-ready goods supplied with credit facilities cannot be equated with raw farmer purchases requiring separate processing, packaging, transport and labour costs. On those facts, deletion of the transfer-pricing adjustment was sustained. Interest disallowance on interest-free advances requires a demonstrated direct nexus with interest-bearing borrowings; substantial interest-free funds and no such nexus supported deletion. Form 26AS interest, net of tax deducted at source, recorded as "Rate Difference" and included in returned income did not establish additional undisclosed income, so the related addition was deleted. en-us Mon, 21 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800397 Comparable Uncontrolled Price Method benchmarking requires materially comparable transactions: processed, sorted, packed and delivered export-ready goods supplied with credit facilities cannot be equated with raw farmer purchases requiring separate processing, packaging, transport and labour costs. On those facts, deletion of the transfer-pricing adjustment was sustained. Interest disallowance on interest-free advances requires a demonstrated direct nexus with interest-bearing borrowings; substantial interest-free funds and no such nexus supported deletion. Form 26AS interest, net of tax deducted at source, recorded as "Rate Difference" and included in returned income did not establish additional undisclosed income, so the related addition was deleted. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800397