https://www.taxtmi.com/caselaws?id=473021 Transactional Net Margin Method analysis may select a foreign associated enterprise as the tested party where it is the least complex, low-risk entity, particularly where materially unchanged facts support a consistent approach. Broad functional similarity can suffice for foreign comparables when identical comparables are unavailable. Any transfer-pricing adjustment should not exceed the margin retained by the associated enterprise in relevant customer transactions. Functionally dissimilar comparables must be excluded; employee-cost and persistent-loss filters may be inappropriate; and remaining margins require computation from annual reports. Working-capital differences in receivables and payables require corresponding adjustment for a reliable arm's-length determination. en-us Fri, 06 Jun 2025 00:00:00 +0530 Sat, 31 Oct 2026 17:44:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=473021 Transactional Net Margin Method analysis may select a foreign associated enterprise as the tested party where it is the least complex, low-risk entity, particularly where materially unchanged facts support a consistent approach. Broad functional similarity can suffice for foreign comparables when identical comparables are unavailable. Any transfer-pricing adjustment should not exceed the margin retained by the associated enterprise in relevant customer transactions. Functionally dissimilar comparables must be excluded; employee-cost and persistent-loss filters may be inappropriate; and remaining margins require computation from annual reports. Working-capital differences in receivables and payables require corresponding adjustment for a reliable arm's-length determination. Case-Laws Income Tax Fri, 06 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=473021