https://www.taxtmi.com/highlights?id=105445 Under TNMM, the comparable set in a transfer-pricing study is not conclusive and may be revised during proceedings; functional comparability depends on functions performed, assets employed and risks assumed. A manufacturing entity was treated as incomparable to a medical-device trader undertaking related research and development activities, requiring recomputation of the arm's length margin. No notional-interest adjustment was warranted on an interest-free loan to an associated enterprise where the advance was commercially expedient in the context of goods sales, on the stated facts. A challenge to proposed penalty proceedings was premature, while an alleged double disallowance required document-based verification before relief. en-us Tue, 27 Oct 2026 14:24:33 +0530 Tue, 27 Oct 2026 14:24:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105445 Under TNMM, the comparable set in a transfer-pricing study is not conclusive and may be revised during proceedings; functional comparability depends on functions performed, assets employed and risks assumed. A manufacturing entity was treated as incomparable to a medical-device trader undertaking related research and development activities, requiring recomputation of the arm's length margin. No notional-interest adjustment was warranted on an interest-free loan to an associated enterprise where the advance was commercially expedient in the context of goods sales, on the stated facts. A challenge to proposed penalty proceedings was premature, while an alleged double disallowance required document-based verification before relief. Highlights Income Tax Tue, 27 Oct 2026 14:24:33 +0530 https://www.taxtmi.com/highlights?id=105445