https://www.taxtmi.com/caselaws?id=210050 ITAT held that courier companies with very low turnover (below 5% and 20%) were not valid comparables due to differences in economies of scale, and their prior-year acceptance did not create res judicata. Segmental results of a large logistics company were rightly rejected since direct comparables were available and segmental accounts may not fully allocate common costs. ITAT agreed in principle that only operating profit should be considered for transfer pricing, and that the nature of insurance and other receipts must be examined to determine if they are operational. The order of DRP was set aside and the matter remitted to TPO for fresh examination; appeal allowed for statistical purposes. en-us Wed, 27 Apr 2011 00:00:00 +0530 Thu, 27 Nov 2025 16:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210050 ITAT held that courier companies with very low turnover (below 5% and 20%) were not valid comparables due to differences in economies of scale, and their prior-year acceptance did not create res judicata. Segmental results of a large logistics company were rightly rejected since direct comparables were available and segmental accounts may not fully allocate common costs. ITAT agreed in principle that only operating profit should be considered for transfer pricing, and that the nature of insurance and other receipts must be examined to determine if they are operational. The order of DRP was set aside and the matter remitted to TPO for fresh examination; appeal allowed for statistical purposes. Case-Laws Income Tax Wed, 27 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210050