Berry Ratio rejected for jewellery manufacturing; receivables interest depends on customer-credit parity and binding book-profit directions.

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....Berry ratio is unsuitable as a profit level indicator for a jewellery manufacturer that bears material, inventory, price and manufacturing risks, because value-added expenses exclude material costs, capital deployment and risks; total cost is the more reliable base. Sales transfer-pricing adjustments based on that ratio were deleted. Notional interest on associated-enterprise receivables requires parity analysis against unrelated customers: where identical 180-day, interest-free credit terms applied, the adjustment was deleted. For a later year, verification was required and any interest confined to delays beyond 180 days at six-month LIBOR plus verified bank spread. Transfer-pricing adjustments could not be included in book profit contrary to binding directions.....