https://www.taxtmi.com/highlights?id=105217 Functional comparability under the CUP method requires comparison of functions performed, assets employed and risks assumed; third-party guarantee data must be disclosed for effective rebuttal. In the absence of reliable comparable uncontrolled transactions or a proper FAR analysis, the transfer-pricing adjustment for counter-guarantee support was deleted. Lending income could not be equally allocated where the overseas entity funded loans and assumed substantive lending risks, and no reliable comparable or prescribed method disproved the attribution. An arm's length price cannot be determined ad hoc after rejecting TNMM without a comparable or prescribed method. Regional support expenditure was supported by evidence of services, business n..... en-us Wed, 21 Oct 2026 08:37:56 +0530 Wed, 21 Oct 2026 08:37:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105217 Functional comparability under the CUP method requires comparison of functions performed, assets employed and risks assumed; third-party guarantee data must be disclosed for effective rebuttal. In the absence of reliable comparable uncontrolled transactions or a proper FAR analysis, the transfer-pricing adjustment for counter-guarantee support was deleted. Lending income could not be equally allocated where the overseas entity funded loans and assumed substantive lending risks, and no reliable comparable or prescribed method disproved the attribution. An arm's length price cannot be determined ad hoc after rejecting TNMM without a comparable or prescribed method. Regional support expenditure was supported by evidence of services, business n..... Highlights Income Tax Wed, 21 Oct 2026 08:37:56 +0530 https://www.taxtmi.com/highlights?id=105217