https://www.taxtmi.com/caselaws?id=257215 Transfer pricing comparability must reflect functional reality, so foreign exchange fluctuation from operating activity is included in operating income or cost, a 75% export filter may be reduced where it distorts comparables, and a functionally different software licence business may be excluded while an export-oriented segment with segmental data may be retained. Comparability objections based on lack of opportunity fail where show-cause notices were issued and heard, and rejection of multiple year data stands where covered by binding authority. On incentive relief, an alternative claim under section 10A can require fresh examination where the statutory conditions were not fully considered, while section 10B eligibility was not finally decided. en-us Tue, 13 Jan 2015 00:00:00 +0530 Thu, 05 Mar 2015 09:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257215 Transfer pricing comparability must reflect functional reality, so foreign exchange fluctuation from operating activity is included in operating income or cost, a 75% export filter may be reduced where it distorts comparables, and a functionally different software licence business may be excluded while an export-oriented segment with segmental data may be retained. Comparability objections based on lack of opportunity fail where show-cause notices were issued and heard, and rejection of multiple year data stands where covered by binding authority. On incentive relief, an alternative claim under section 10A can require fresh examination where the statutory conditions were not fully considered, while section 10B eligibility was not finally decided. Case-Laws Income Tax Tue, 13 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257215