https://www.taxtmi.com/caselaws?id=210190 ITAT (HYD) upheld most transfer-pricing adjustments, ruling ALP must be determined using contemporaneous single-year data per r.10B(4), and directed fresh comparable searches when current-year data were unavailable. The 5% tolerance is not a rote deduction; actual arithmetic mean governs adjustments. Several challenged comparables were upheld; one comparable was excluded for excessive related-party turnover. Differences in accounting policies and certain comparable exclusions were found inadmissible for lack of prior objection. TP rules apply irrespective of any proven profit-shifting motive. Telecommunication charges excluded from export turnover must also be excluded when computing allowable s.10A deduction. en-us Fri, 22 Jul 2011 00:00:00 +0530 Thu, 21 Aug 2025 15:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210190 ITAT (HYD) upheld most transfer-pricing adjustments, ruling ALP must be determined using contemporaneous single-year data per r.10B(4), and directed fresh comparable searches when current-year data were unavailable. The 5% tolerance is not a rote deduction; actual arithmetic mean governs adjustments. Several challenged comparables were upheld; one comparable was excluded for excessive related-party turnover. Differences in accounting policies and certain comparable exclusions were found inadmissible for lack of prior objection. TP rules apply irrespective of any proven profit-shifting motive. Telecommunication charges excluded from export turnover must also be excluded when computing allowable s.10A deduction. Case-Laws Income Tax Fri, 22 Jul 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210190