https://www.taxtmi.com/caselaws?id=212081 The Tribunal upheld the CIT(A)'s decision to exclude loss-making companies from comparables for determining profit margins under the TNMM method. Abnormal expenses like connectivity and database costs were deemed to distort margins, making data unreliable for analysis. Only functionally similar comparables were considered, with adjustments made for accuracy. The Tribunal stressed the significance of accurate adjustments and comparability in determining the Arm's Length Price, dismissing the appeal and affirming the approach taken by the CIT(A). en-us Wed, 25 Jan 2012 00:00:00 +0530 Fri, 13 Apr 2012 08:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212081 The Tribunal upheld the CIT(A)'s decision to exclude loss-making companies from comparables for determining profit margins under the TNMM method. Abnormal expenses like connectivity and database costs were deemed to distort margins, making data unreliable for analysis. Only functionally similar comparables were considered, with adjustments made for accuracy. The Tribunal stressed the significance of accurate adjustments and comparability in determining the Arm's Length Price, dismissing the appeal and affirming the approach taken by the CIT(A). Case-Laws Income Tax Wed, 25 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212081