https://www.taxtmi.com/caselaws?id=259068 The HC held that comparables with exceptionally high profit margins cannot be excluded solely on that basis; a Rule 10B(3) analysis must determine if material differences can be eliminated. Brescon and Khandwala Securities were deemed functionally similar and remitted to the DRP for such analysis. Keynote was found functionally dissimilar due to differing activities and remanded for reconsideration of comparability under Rule 10B(2)(b). The Court allowed deduction under Section 36(1)(ii) for bonuses paid to shareholder-directors, rejecting revenue's claim that payments were disguised dividends to avoid tax. The matter was remitted for fresh determination consistent with these principles, resulting in a decision favorable to the assessee. en-us Mon, 27 Apr 2015 00:00:00 +0530 Mon, 28 Jul 2025 16:13:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259068 The HC held that comparables with exceptionally high profit margins cannot be excluded solely on that basis; a Rule 10B(3) analysis must determine if material differences can be eliminated. Brescon and Khandwala Securities were deemed functionally similar and remitted to the DRP for such analysis. Keynote was found functionally dissimilar due to differing activities and remanded for reconsideration of comparability under Rule 10B(2)(b). The Court allowed deduction under Section 36(1)(ii) for bonuses paid to shareholder-directors, rejecting revenue's claim that payments were disguised dividends to avoid tax. The matter was remitted for fresh determination consistent with these principles, resulting in a decision favorable to the assessee. Case-Laws Income Tax Mon, 27 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259068