https://www.taxtmi.com/caselaws?id=801389 Transfer-pricing analysis of banking services requires demonstrable functional, asset and risk comparability, a reliable prescribed method, and an effective opportunity to rebut third-party data obtained under section 133(6). Counter-guarantee pricing should distinguish an intermediary's role from that of a guarantor bank. Attribution of ECB interest and fee income should reflect each entity's funding, lending functions and assumption of credit, liquidity and interest-rate risks. Regional support and head-office expense charges require evidence of services received, business benefit, cost base and allocation methodology. Mark-to-market treatment of AFS and HFT investments held as stock-in-trade and consistently valued at lower of cost or market value concerns whether diminution is a trading loss rather than an unascertained-liability provision. 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=801389 Transfer-pricing analysis of banking services requires demonstrable functional, asset and risk comparability, a reliable prescribed method, and an effective opportunity to rebut third-party data obtained under section 133(6). Counter-guarantee pricing should distinguish an intermediary's role from that of a guarantor bank. Attribution of ECB interest and fee income should reflect each entity's funding, lending functions and assumption of credit, liquidity and interest-rate risks. Regional support and head-office expense charges require evidence of services received, business benefit, cost base and allocation methodology. Mark-to-market treatment of AFS and HFT investments held as stock-in-trade and consistently valued at lower of cost or market value concerns whether diminution is a trading loss rather than an unascertained-liability provision. Case-Laws Income Tax Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801389