https://www.taxtmi.com/caselaws?id=247028 The ITAT Bangalore ruled largely in favor of the assessee on multiple transfer pricing issues. It held that turnover filters must exclude significantly larger companies to ensure comparability, rejecting the TPO's inclusion of outsized comparables. Functionally different companies were deemed non-comparable without proper adjustments. Foreign exchange gains/losses were to be included in operating costs. The working capital adjustment issue was remitted for fresh verification. Risk adjustment computations were to be verified, with adjustments mandated if margins differed beyond the 5% threshold under s. 92C(2). For deduction under s. 10A, expenses reduced from export turnover must also reduce total turnover to maintain parity. Prior period expenses unrelated to the assessment year were disallowed. Overall, directions favored the assessee with remands for factual verification and adherence to established precedents. en-us Fri, 21 Dec 2012 00:00:00 +0530 Mon, 11 Aug 2025 15:18:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247028 The ITAT Bangalore ruled largely in favor of the assessee on multiple transfer pricing issues. It held that turnover filters must exclude significantly larger companies to ensure comparability, rejecting the TPO's inclusion of outsized comparables. Functionally different companies were deemed non-comparable without proper adjustments. Foreign exchange gains/losses were to be included in operating costs. The working capital adjustment issue was remitted for fresh verification. Risk adjustment computations were to be verified, with adjustments mandated if margins differed beyond the 5% threshold under s. 92C(2). For deduction under s. 10A, expenses reduced from export turnover must also reduce total turnover to maintain parity. Prior period expenses unrelated to the assessment year were disallowed. Overall, directions favored the assessee with remands for factual verification and adherence to established precedents. Case-Laws Income Tax Fri, 21 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247028