https://www.taxtmi.com/caselaws?id=800896 Rule 10B(3) permits an uncontrolled transaction to serve as a comparable only where material differences do not affect profit or can be neutralised through reasonably accurate adjustments. Capacity underutilisation, resulting depreciation differences, and customs-duty burdens require examination against audited data, together with functional comparability, in manufacturing-segment benchmarking; the adjustment requires fresh arm's-length determination. ECB interest remains subject to section 92C benchmarking despite RBI all-in-cost compliance. A single transaction with materially different credit profile, scale and risk attributes is not a reliable benchmark, requiring fresh comparability analysis after an opportunity to substantiate claims. en-us Thu, 01 Oct 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800896 Rule 10B(3) permits an uncontrolled transaction to serve as a comparable only where material differences do not affect profit or can be neutralised through reasonably accurate adjustments. Capacity underutilisation, resulting depreciation differences, and customs-duty burdens require examination against audited data, together with functional comparability, in manufacturing-segment benchmarking; the adjustment requires fresh arm's-length determination. ECB interest remains subject to section 92C benchmarking despite RBI all-in-cost compliance. A single transaction with materially different credit profile, scale and risk attributes is not a reliable benchmark, requiring fresh comparability analysis after an opportunity to substantiate claims. Case-Laws Income Tax Thu, 01 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800896