https://www.taxtmi.com/caselaws?id=237053 Transfer pricing comparables must be screened for functional similarity, turnover relevance and reliable segmental data, so companies lacking comparability or verifiable segments may be excluded or sent back for fresh examination. For section 10A computation, foreign exchange gain from services was treated as business income, communication or leased line charges attributable to exports were to be excluded from export and total turnover, overseas branch profits could be considered subject to verification, and treaty-based foreign tax credit could not be denied in principle. Reimbursements to associated enterprises for travel-related costs were held outside operating cost under TNMM, while interest under sections 234B and 234D was treated as consequential. en-us Fri, 28 Jun 2013 00:00:00 +0530 Tue, 17 Sep 2013 08:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237053 Transfer pricing comparables must be screened for functional similarity, turnover relevance and reliable segmental data, so companies lacking comparability or verifiable segments may be excluded or sent back for fresh examination. For section 10A computation, foreign exchange gain from services was treated as business income, communication or leased line charges attributable to exports were to be excluded from export and total turnover, overseas branch profits could be considered subject to verification, and treaty-based foreign tax credit could not be denied in principle. Reimbursements to associated enterprises for travel-related costs were held outside operating cost under TNMM, while interest under sections 234B and 234D was treated as consequential. Case-Laws Income Tax Fri, 28 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237053