https://www.taxtmi.com/caselaws?id=472983 Transfer-pricing analysis under the Transactional Net Margin Method requires turnover and functional comparability: high-turnover, diversified, product-based, or otherwise functionally distinct entities should be excluded, and working-capital adjustments calculated from actual data should not be arbitrarily capped. A timely reference to the Transfer Pricing Officer triggers the extended assessment limitation period. For Section 10A, expenditure excluded from export turnover must also be excluded from total turnover, and the deduction is computed undertaking-wise before gross-total-income reductions, subject to verification of relevant figures. Employee misappropriation incidental to business may be deductible in the year discovered, subject to evaluation of recovery evidence and consequential adjustment to eligible undertaking profits. en-us Wed, 15 Dec 2021 00:00:00 +0530 Fri, 30 Oct 2026 18:58:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472983 Transfer-pricing analysis under the Transactional Net Margin Method requires turnover and functional comparability: high-turnover, diversified, product-based, or otherwise functionally distinct entities should be excluded, and working-capital adjustments calculated from actual data should not be arbitrarily capped. A timely reference to the Transfer Pricing Officer triggers the extended assessment limitation period. For Section 10A, expenditure excluded from export turnover must also be excluded from total turnover, and the deduction is computed undertaking-wise before gross-total-income reductions, subject to verification of relevant figures. Employee misappropriation incidental to business may be deductible in the year discovered, subject to evaluation of recovery evidence and consequential adjustment to eligible undertaking profits. Case-Laws Income Tax Wed, 15 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472983