https://www.taxtmi.com/caselaws?id=259906 A comparable can be excluded under TNMM where functional dissimilarity is shown by abnormal business characteristics; Excel Infoways Ltd. was rejected because its unusually low employee cost base and high margin made it unreliable, and the transfer pricing adjustment fell once the remaining comparables were tested. A DRP-directed deduction under section 10(35) had to be given effect, so the Assessing Officer was required to allow it. A section 14A read with Rule 8D disallowance was deleted because the computation was based on factual error in valuing mutual fund units. Advance tax credit was remanded for verification of challans, while interest under sections 234B and 234C was held mandatory and consequential. en-us Fri, 06 Feb 2015 00:00:00 +0530 Tue, 26 May 2015 07:47:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259906 A comparable can be excluded under TNMM where functional dissimilarity is shown by abnormal business characteristics; Excel Infoways Ltd. was rejected because its unusually low employee cost base and high margin made it unreliable, and the transfer pricing adjustment fell once the remaining comparables were tested. A DRP-directed deduction under section 10(35) had to be given effect, so the Assessing Officer was required to allow it. A section 14A read with Rule 8D disallowance was deleted because the computation was based on factual error in valuing mutual fund units. Advance tax credit was remanded for verification of challans, while interest under sections 234B and 234C was held mandatory and consequential. Case-Laws Income Tax Fri, 06 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259906