https://www.taxtmi.com/caselaws?id=202618 ITAT upheld the CIT(A)'s rejection of additional comparables proposed by the assessee, agreeing that companies with related party transactions exceeding 25% of sales and functional differences could not be used under TNMM. It confirmed that only current-year data, with limited exceptions under Rule 10B(4), is permissible, and subsequent period data cannot be used. On section 10A, it approved reducing data link charges from both export turnover and total turnover in line with Sak Soft. However, it reversed the CIT(A) on the 5% adjustment under section 92C(2), holding it inapplicable where ALP is determined by a single method and single price. Both assessee's and Revenue's appeals were partly allowed. en-us Fri, 25 Feb 2011 00:00:00 +0530 Wed, 26 Nov 2025 14:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=202618 ITAT upheld the CIT(A)'s rejection of additional comparables proposed by the assessee, agreeing that companies with related party transactions exceeding 25% of sales and functional differences could not be used under TNMM. It confirmed that only current-year data, with limited exceptions under Rule 10B(4), is permissible, and subsequent period data cannot be used. On section 10A, it approved reducing data link charges from both export turnover and total turnover in line with Sak Soft. However, it reversed the CIT(A) on the 5% adjustment under section 92C(2), holding it inapplicable where ALP is determined by a single method and single price. Both assessee's and Revenue's appeals were partly allowed. Case-Laws Income Tax Fri, 25 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=202618