https://www.taxtmi.com/caselaws?id=802105 Transfer-pricing margins under the Transactional Net Margin Method treat trade-receivable bad-debt provisions, rates and taxes, business-related receipts, and deferred operating-revenue amortisation as operating items. Comparable selection requires functional, asset and risk analysis, uniform related-party transaction filtering, and exclusion of entities affected by extraordinary events, high-end functions, or materially different scale. Distribution adjustments remain limited to associated-enterprise transactions and use gross-margin comparison under the Resale Price Method. Working-capital differences require average-balance analysis. Delayed associated-enterprise receivables do not warrant notional interest without demonstrated financing cost, arrangement, or benefit. Intra-group services cannot be priced at nil without valid method selection, comparability analysis, or evidence of shareholder activity; the segmental computation requires recomputation accordingly. en-us Mon, 07 Sep 2026 00:00:00 +0530 Sat, 31 Oct 2026 08:32:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802105 Transfer-pricing margins under the Transactional Net Margin Method treat trade-receivable bad-debt provisions, rates and taxes, business-related receipts, and deferred operating-revenue amortisation as operating items. Comparable selection requires functional, asset and risk analysis, uniform related-party transaction filtering, and exclusion of entities affected by extraordinary events, high-end functions, or materially different scale. Distribution adjustments remain limited to associated-enterprise transactions and use gross-margin comparison under the Resale Price Method. Working-capital differences require average-balance analysis. Delayed associated-enterprise receivables do not warrant notional interest without demonstrated financing cost, arrangement, or benefit. Intra-group services cannot be priced at nil without valid method selection, comparability analysis, or evidence of shareholder activity; the segmental computation requires recomputation accordingly. Case-Laws Income Tax Mon, 07 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802105