https://www.taxtmi.com/caselaws?id=801390 Timely issuance of a draft assessment order attracts the separate final-order timelines prescribed for DRP directions, notwithstanding the general assessment limitation. Tax computation must conform to assessed nil income after set-off of brought-forward losses and unabsorbed depreciation, subject to verification of year-wise utilisation. For traded goods purchased from associated enterprises and resold independently, RPM remains appropriate absent material processing, substantial value addition, or defects in gross-margin comparables; a comparable with verifiable gross-profit data cannot be rejected solely under TNMM profitability criteria. A commercially justified weighted NAV-DCF valuation may determine the arm's length price of an operating-business transfer where neither NAV nor DCF should receive exclusive weight. A transaction deemed international does not alone establish associated-enterprise status for secondary adjustment; refund eligibility requires verification of that relationship. en-us Wed, 30 Sep 2026 00:00:00 +0530 Wed, 21 Oct 2026 08:37:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801390 Timely issuance of a draft assessment order attracts the separate final-order timelines prescribed for DRP directions, notwithstanding the general assessment limitation. Tax computation must conform to assessed nil income after set-off of brought-forward losses and unabsorbed depreciation, subject to verification of year-wise utilisation. For traded goods purchased from associated enterprises and resold independently, RPM remains appropriate absent material processing, substantial value addition, or defects in gross-margin comparables; a comparable with verifiable gross-profit data cannot be rejected solely under TNMM profitability criteria. A commercially justified weighted NAV-DCF valuation may determine the arm's length price of an operating-business transfer where neither NAV nor DCF should receive exclusive weight. A transaction deemed international does not alone establish associated-enterprise status for secondary adjustment; refund eligibility requires verification of that relationship. Case-Laws Income Tax Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801390