https://www.taxtmi.com/caselaws?id=251117 ITAT held that transfer-pricing comparability must use data of the financial year in which the international transaction occurred (with preceding two years usable only if relevant), upholding the TPO's use of the current year data. Abnormal loss-making and anomalous comparables (including firms with atypical employee-cost ratios) were to be excluded; certain comparables were directed to be included. Related-party transactions were not automatically disqualified on the facts. Segmental data may be used for net-margin computation. Payments to an ISP involving technical personnel were treated as fees for technical services, attracting TDS consequences and disallowance. An ad-hoc 15% disallowance was upheld for failure to produce records. en-us Mon, 26 Nov 2012 00:00:00 +0530 Mon, 10 Nov 2025 13:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251117 ITAT held that transfer-pricing comparability must use data of the financial year in which the international transaction occurred (with preceding two years usable only if relevant), upholding the TPO's use of the current year data. Abnormal loss-making and anomalous comparables (including firms with atypical employee-cost ratios) were to be excluded; certain comparables were directed to be included. Related-party transactions were not automatically disqualified on the facts. Segmental data may be used for net-margin computation. Payments to an ISP involving technical personnel were treated as fees for technical services, attracting TDS consequences and disallowance. An ad-hoc 15% disallowance was upheld for failure to produce records. Case-Laws Income Tax Mon, 26 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251117