https://www.taxtmi.com/caselaws?id=802479 Transfer pricing characterisation and comparability depend on the actual functions performed, assets employed and risks assumed by the relevant business segment. Ancillary dry blending to customer-provided formulations, without substantial product transformation, does not by itself justify treating an entire distribution business as manufacturing or applying manufacturing comparables to it. Accounting classifications and machinery alone do not determine the functional profile. The functions and risks of a separate marketing support services segment cannot automatically be attributed to the distribution segment. Benchmarking under the transactional net margin method must reflect the relevant segment's functional profile. en-us Tue, 13 Oct 2026 00:00:00 +0530 Fri, 06 Nov 2026 08:29:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802479 Transfer pricing characterisation and comparability depend on the actual functions performed, assets employed and risks assumed by the relevant business segment. Ancillary dry blending to customer-provided formulations, without substantial product transformation, does not by itself justify treating an entire distribution business as manufacturing or applying manufacturing comparables to it. Accounting classifications and machinery alone do not determine the functional profile. The functions and risks of a separate marketing support services segment cannot automatically be attributed to the distribution segment. Benchmarking under the transactional net margin method must reflect the relevant segment's functional profile. Case-Laws Income Tax Tue, 13 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802479