https://www.taxtmi.com/caselaws?id=800886 Functional comparability governs benchmarking of business-support and general-management services between associated enterprises. Under the arm's length framework, comparables must reflect the functions performed, assets employed and risks assumed in the specific controlled transaction; use of the Transactional Net Margin Method does not remove this requirement. Healthcare or hospital operating entities cannot be selected solely because the service provider operates in the healthcare sector. Contractual terms, invoices and contemporaneous evidence must establish the services actually rendered and the precise functions performed. The arm's length price requires fresh determination using entities functionally comparable to the support and management services. en-us Mon, 21 Sep 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800886 Functional comparability governs benchmarking of business-support and general-management services between associated enterprises. Under the arm's length framework, comparables must reflect the functions performed, assets employed and risks assumed in the specific controlled transaction; use of the Transactional Net Margin Method does not remove this requirement. Healthcare or hospital operating entities cannot be selected solely because the service provider operates in the healthcare sector. Contractual terms, invoices and contemporaneous evidence must establish the services actually rendered and the precise functions performed. The arm's length price requires fresh determination using entities functionally comparable to the support and management services. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800886