https://www.taxtmi.com/caselaws?id=217841 Transfer pricing benchmarking under Rule 10B(4) should primarily use current-year data, with earlier years considered only in the limited statutory circumstances, and working capital differences require adjustment where they distort operating profitability. The Tribunal also applied FAR analysis to exclude non-comparable companies where functional dissimilarity, exceptional turnover, related party transactions or volatile margins made comparability unreliable. On that basis, working capital adjustment was directed and the adjustment was recomputed after removing identified comparables that did not meet the comparability standard. en-us Fri, 12 Oct 2012 00:00:00 +0530 Mon, 27 May 2013 16:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217841 Transfer pricing benchmarking under Rule 10B(4) should primarily use current-year data, with earlier years considered only in the limited statutory circumstances, and working capital differences require adjustment where they distort operating profitability. The Tribunal also applied FAR analysis to exclude non-comparable companies where functional dissimilarity, exceptional turnover, related party transactions or volatile margins made comparability unreliable. On that basis, working capital adjustment was directed and the adjustment was recomputed after removing identified comparables that did not meet the comparability standard. Case-Laws Income Tax Fri, 12 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217841