https://www.taxtmi.com/caselaws?id=253587 Loans from a related party, where no interest is actually paid or received, do not constitute related party transactions for applying the RPT filter because such financing does not directly impact operating profitability; consequently, no hypothetical interest could be added and the concerned company qualified within the 25% RPT threshold and was included as a comparable. A company operating in retail was held functionally incomparable to an assessee engaged in wholesale diamond-studded jewellery business and was excluded. Another company was excluded because segmental operating profit and capital employed for the relevant jewellery segment were unascertainable and sales figures were inconsistent. RoCE was rejected as the PLI under TNMM due to impracticability of reliably identifying AE-specific capital employed/profitability, and the matter was remitted with directions to confine any TP adjustment only to AE international transactions. en-us Tue, 23 Apr 2013 00:00:00 +0530 Wed, 31 Dec 2025 10:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253587 Loans from a related party, where no interest is actually paid or received, do not constitute related party transactions for applying the RPT filter because such financing does not directly impact operating profitability; consequently, no hypothetical interest could be added and the concerned company qualified within the 25% RPT threshold and was included as a comparable. A company operating in retail was held functionally incomparable to an assessee engaged in wholesale diamond-studded jewellery business and was excluded. Another company was excluded because segmental operating profit and capital employed for the relevant jewellery segment were unascertainable and sales figures were inconsistent. RoCE was rejected as the PLI under TNMM due to impracticability of reliably identifying AE-specific capital employed/profitability, and the matter was remitted with directions to confine any TP adjustment only to AE international transactions. Case-Laws Income Tax Tue, 23 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253587