https://www.taxtmi.com/caselaws?id=801322 Transfer-pricing benchmarking of an integrated IT-enabled/data analytics transaction must follow the selected most appropriate method under Section 92C and Rule 10C. Once the Residual Profit Split Method has been fully applied, a separate entity-level TNMM-type margin test for the same transaction is impermissible unless that method is rejected for cogent reasons and an alternative is selected. The separate integrated-services adjustment was deleted. Corporate guarantee pricing cannot mechanically use commercial bank-guarantee rates; an interest-saving analysis requires verification of credit profile, borrowing terms, currency, tenure, security, coverage and economic benefit. Guarantee remuneration was remitted for fresh evidence-based computation. en-us Mon, 21 Sep 2026 00:00:00 +0530 Mon, 19 Oct 2026 07:01:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801322 Transfer-pricing benchmarking of an integrated IT-enabled/data analytics transaction must follow the selected most appropriate method under Section 92C and Rule 10C. Once the Residual Profit Split Method has been fully applied, a separate entity-level TNMM-type margin test for the same transaction is impermissible unless that method is rejected for cogent reasons and an alternative is selected. The separate integrated-services adjustment was deleted. Corporate guarantee pricing cannot mechanically use commercial bank-guarantee rates; an interest-saving analysis requires verification of credit profile, borrowing terms, currency, tenure, security, coverage and economic benefit. Guarantee remuneration was remitted for fresh evidence-based computation. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801322