https://www.taxtmi.com/caselaws?id=258704 ITAT MUMBAI - AT directed the AO to exclude a one-time ESOP cost when computing the TNMM margin (net margin ~16.6% to be verified), ordered consideration of new comparables submitted to the DRP but rejected several on turnover/subsidiary grounds, and upheld the original set of comparables selected by the AO/TPO. The Tribunal held working-capital adjustments (using average receivables/payables) are required and must be made after examination and hearing. It rejected the Revenue's contention that evidence of profit shifting to a low-tax jurisdiction alters ALP. Decision partly for the assessee. en-us Thu, 28 Feb 2013 00:00:00 +0530 Fri, 07 Nov 2025 14:39:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258704 ITAT MUMBAI - AT directed the AO to exclude a one-time ESOP cost when computing the TNMM margin (net margin ~16.6% to be verified), ordered consideration of new comparables submitted to the DRP but rejected several on turnover/subsidiary grounds, and upheld the original set of comparables selected by the AO/TPO. The Tribunal held working-capital adjustments (using average receivables/payables) are required and must be made after examination and hearing. It rejected the Revenue's contention that evidence of profit shifting to a low-tax jurisdiction alters ALP. Decision partly for the assessee. Case-Laws Income Tax Thu, 28 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258704