https://www.taxtmi.com/caselaws?id=328881 Transfer pricing analysis under Chapter X must be confined to international transactions with associated enterprises, so any adjustment based on entity-level sales that includes non-associated enterprise transactions is impermissible and requires recomputation. Comparables must also be examined on a proper functional basis, and where the Transfer Pricing Officer has not fairly considered the assessee's proposed comparable or other identified companies, the issue calls for fresh comparability review. Working capital adjustment is allowable in principle because it addresses differences in inventory, receivables and payables that affect margins, and it must be recomputed on the relevant data after hearing the assessee. en-us Wed, 11 May 2016 00:00:00 +0530 Thu, 16 Jun 2016 20:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328881 Transfer pricing analysis under Chapter X must be confined to international transactions with associated enterprises, so any adjustment based on entity-level sales that includes non-associated enterprise transactions is impermissible and requires recomputation. Comparables must also be examined on a proper functional basis, and where the Transfer Pricing Officer has not fairly considered the assessee's proposed comparable or other identified companies, the issue calls for fresh comparability review. Working capital adjustment is allowable in principle because it addresses differences in inventory, receivables and payables that affect margins, and it must be recomputed on the relevant data after hearing the assessee. Case-Laws Income Tax Wed, 11 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328881