https://www.taxtmi.com/caselaws?id=234288 ITAT, PUNE allowed the appeal, holding the Revenue's transfer pricing adjustment excessive and directing exclusion of certain comparables from the benchmarking set. The tribunal found the TPO erred in including companies that breached the assessee's accepted filters (related-party transactions threshold, functional profile and R&D intensity) and ordered exclusion of those comparables, including the product-oriented and functionally non-comparable entities. The tribunal also allowed the assessee the +/-5% safe-harbour under section 92C(2), concluding the declared margin was at arm's length once the improper comparables were removed. en-us Wed, 30 Nov 2011 00:00:00 +0530 Tue, 19 Aug 2025 15:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234288 ITAT, PUNE allowed the appeal, holding the Revenue's transfer pricing adjustment excessive and directing exclusion of certain comparables from the benchmarking set. The tribunal found the TPO erred in including companies that breached the assessee's accepted filters (related-party transactions threshold, functional profile and R&D intensity) and ordered exclusion of those comparables, including the product-oriented and functionally non-comparable entities. The tribunal also allowed the assessee the +/-5% safe-harbour under section 92C(2), concluding the declared margin was at arm's length once the improper comparables were removed. Case-Laws Income Tax Wed, 30 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234288