https://www.taxtmi.com/caselaws?id=472298 Transfer-pricing benchmarking under the Transactional Net Margin Method requires a disclosed, reasoned functional, asset and risk analysis to support comparable-company exclusions and selections across distribution, software-development and technical-support segments. Absent that analysis, comparability determinations require fresh, transparent evaluation with an opportunity to submit evidence. Deferred payment or receivables exceeding the agreed credit period constitute a separate international transaction, because only credit within that period is embedded in the sale price. Foreign-currency delayed receivables require separate interest benchmarking at LIBOR plus a 200-basis-point spread. en-us Mon, 10 Mar 2025 00:00:00 +0530 Wed, 07 Oct 2026 13:42:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472298 Transfer-pricing benchmarking under the Transactional Net Margin Method requires a disclosed, reasoned functional, asset and risk analysis to support comparable-company exclusions and selections across distribution, software-development and technical-support segments. Absent that analysis, comparability determinations require fresh, transparent evaluation with an opportunity to submit evidence. Deferred payment or receivables exceeding the agreed credit period constitute a separate international transaction, because only credit within that period is embedded in the sale price. Foreign-currency delayed receivables require separate interest benchmarking at LIBOR plus a 200-basis-point spread. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472298