https://www.taxtmi.com/caselaws?id=239790 The ITAT Mumbai held that the TPO acted within statutory limits in selecting comparables for transfer pricing adjustments but criticized the inclusion of large companies like Infosys and Wipro as inappropriate due to differences in service nature, risk, and scale, remanding the issue for fresh adjudication. Loss-making companies were deemed unsuitable comparables under TNMM without proper justification, and the assessee bears the burden to explain extreme profits or losses. The treatment of foreign exchange loss on interest was upheld in favor of the assessee. However, the Revenue's rejection of working capital and risk adjustments lacked proper reasoning, leading to remand. Overall, the matter was partially decided against the assessee with directions for reconsideration on comparability and adjustments. en-us Wed, 06 Nov 2013 00:00:00 +0530 Fri, 01 Aug 2025 12:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239790 The ITAT Mumbai held that the TPO acted within statutory limits in selecting comparables for transfer pricing adjustments but criticized the inclusion of large companies like Infosys and Wipro as inappropriate due to differences in service nature, risk, and scale, remanding the issue for fresh adjudication. Loss-making companies were deemed unsuitable comparables under TNMM without proper justification, and the assessee bears the burden to explain extreme profits or losses. The treatment of foreign exchange loss on interest was upheld in favor of the assessee. However, the Revenue's rejection of working capital and risk adjustments lacked proper reasoning, leading to remand. Overall, the matter was partially decided against the assessee with directions for reconsideration on comparability and adjustments. Case-Laws Income Tax Wed, 06 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239790