https://www.taxtmi.com/caselaws?id=236867 ITAT AHMEDABAD held largely for revenue: Chapter X focuses on determining ALP for Indian cross-border transactions regardless of AE's foreign losses; the assessee's external comparables were rejected for product dissimilarity and alleged cherry-picking, placing on TPO the duty to select closest public comparables (a single valid comparable may suffice). Use of information gathered under s.133(6)/92CA(7) was permissible once disclosed to the assessee. However, the tribunal accepted that an internal comparable under TNMM can be considered after adjustments where domestic and export transactions by the same taxpayer are sufficiently similar. en-us Fri, 28 Jun 2013 00:00:00 +0530 Thu, 09 Oct 2025 13:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236867 ITAT AHMEDABAD held largely for revenue: Chapter X focuses on determining ALP for Indian cross-border transactions regardless of AE's foreign losses; the assessee's external comparables were rejected for product dissimilarity and alleged cherry-picking, placing on TPO the duty to select closest public comparables (a single valid comparable may suffice). Use of information gathered under s.133(6)/92CA(7) was permissible once disclosed to the assessee. However, the tribunal accepted that an internal comparable under TNMM can be considered after adjustments where domestic and export transactions by the same taxpayer are sufficiently similar. Case-Laws Income Tax Fri, 28 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236867