https://www.taxtmi.com/caselaws?id=802541 Transfer-pricing benchmarking of non-DMA brokerage commissions requires consideration of differences in services provided to associated enterprises and unrelated clients. Broader marketing, sales support, research and relationship services for unrelated clients support TNMM rather than an unadjusted internal CUP comparison, and removal of the resulting brokerage adjustment. For non-binding investment sub-advisory services, comparability depends on functions, risks and economic circumstances. The revised comparable set excludes providers engaged in technology outsourcing, unsegmented portfolio management, investment banking and infrastructure consultancy, as well as a company restructured during the relevant year. A consultancy operating across sectors is included based on its core advisory function, and the sub-advisory margin must be recomputed. en-us Wed, 14 Oct 2026 00:00:00 +0530 Sat, 07 Nov 2026 08:22:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802541 Transfer-pricing benchmarking of non-DMA brokerage commissions requires consideration of differences in services provided to associated enterprises and unrelated clients. Broader marketing, sales support, research and relationship services for unrelated clients support TNMM rather than an unadjusted internal CUP comparison, and removal of the resulting brokerage adjustment. For non-binding investment sub-advisory services, comparability depends on functions, risks and economic circumstances. The revised comparable set excludes providers engaged in technology outsourcing, unsegmented portfolio management, investment banking and infrastructure consultancy, as well as a company restructured during the relevant year. A consultancy operating across sectors is included based on its core advisory function, and the sub-advisory margin must be recomputed. Case-Laws Income Tax Wed, 14 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802541