https://www.taxtmi.com/highlights?id=104903 Rule 10B(3) requires examination of differences that materially affect net profit margins and reasonably accurate comparability adjustments where quantification is possible. Capacity underutilisation and differing customs-duty burdens may distort manufacturing-segment profitability, but claims require complete quantitative and documentary support and fresh functional comparability analysis. Regulatory ceilings for external commercial borrowings do not replace transfer-pricing arm's-length benchmarking; interest comparables must reflect materially similar credit profile, scale and risk attributes rather than rely on a single unsuitable comparable. Penalty proceedings for under-reporting, misreporting or alleged false entries remain separate from assessment proceedings, making a challenge to their initiation premature. en-us Tue, 13 Oct 2026 10:15:19 +0530 Tue, 13 Oct 2026 10:15:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104903 Rule 10B(3) requires examination of differences that materially affect net profit margins and reasonably accurate comparability adjustments where quantification is possible. Capacity underutilisation and differing customs-duty burdens may distort manufacturing-segment profitability, but claims require complete quantitative and documentary support and fresh functional comparability analysis. Regulatory ceilings for external commercial borrowings do not replace transfer-pricing arm's-length benchmarking; interest comparables must reflect materially similar credit profile, scale and risk attributes rather than rely on a single unsuitable comparable. Penalty proceedings for under-reporting, misreporting or alleged false entries remain separate from assessment proceedings, making a challenge to their initiation premature. Highlights Income Tax Tue, 13 Oct 2026 10:15:19 +0530 https://www.taxtmi.com/highlights?id=104903