https://www.taxtmi.com/caselaws?id=348267 Transfer pricing comparability must be tested on functional similarity, assets employed, risks assumed and reliable segmental data, so government/public sector entities, diversified businesses and companies with materially different related-party exposure may be excluded, while comparable entities may be included or remitted for verification where factual data needs confirmation. On section 144C(8), the Dispute Resolution Panel is not ? need English. The Panel can address a disallowance arising from the draft assessment proceedings even if it was not separately proposed in the draft order. A disallowance under section 40(a)(i) based on reimbursement-type travel, conveyance, salary, allowance and payroll administration payments requires fresh factual verification by the Assessing Officer before final computation. en-us Tue, 12 Sep 2017 00:00:00 +0530 Tue, 19 Sep 2017 15:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=348267 Transfer pricing comparability must be tested on functional similarity, assets employed, risks assumed and reliable segmental data, so government/public sector entities, diversified businesses and companies with materially different related-party exposure may be excluded, while comparable entities may be included or remitted for verification where factual data needs confirmation. On section 144C(8), the Dispute Resolution Panel is not ? need English. The Panel can address a disallowance arising from the draft assessment proceedings even if it was not separately proposed in the draft order. A disallowance under section 40(a)(i) based on reimbursement-type travel, conveyance, salary, allowance and payroll administration payments requires fresh factual verification by the Assessing Officer before final computation. Case-Laws Income Tax Tue, 12 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=348267