https://www.taxtmi.com/caselaws?id=472449 Transfer-pricing comparability under the Transactional Net Margin Method requires exclusion of manufacturing entities outside the tested party's turnover range where size materially affects margins, and any adjustment must be limited to international transactions between associated enterprises. Cash-profit indicators may be used where depreciation policies materially differ, subject to verification of their effect on margins. Conversion of an established external borrowing into share capital by book entry, without fresh cash receipt, is not unexplained cash credit when creditor identity, source and loan genuineness are established. Information technology and corporate service fees require verification of supporting evidence. Employee PF/ESI contributions are deductible only if paid by the due date under the relevant enactment, subject to payment verification. en-us Thu, 23 Feb 2023 00:00:00 +0530 Tue, 13 Oct 2026 18:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472449 Transfer-pricing comparability under the Transactional Net Margin Method requires exclusion of manufacturing entities outside the tested party's turnover range where size materially affects margins, and any adjustment must be limited to international transactions between associated enterprises. Cash-profit indicators may be used where depreciation policies materially differ, subject to verification of their effect on margins. Conversion of an established external borrowing into share capital by book entry, without fresh cash receipt, is not unexplained cash credit when creditor identity, source and loan genuineness are established. Information technology and corporate service fees require verification of supporting evidence. Employee PF/ESI contributions are deductible only if paid by the due date under the relevant enactment, subject to payment verification. Case-Laws Income Tax Thu, 23 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472449