https://www.taxtmi.com/caselaws?id=197005 Transfer pricing comparability under internal TNMM requires genuine functional similarity; material differences in technology, brand strength, marketing, procurement, risk profile and R&D intensity justify rejection of segmented comparison. Operating profit for the manufacturing segment must reflect the true character of receipts, so BMSS income was excluded, market promotion fees were included, and other disputed items were remitted for factual verification where their operating nature was unclear. Adjustment could not be confined only to international transactions. For MAT, provision for wealth-tax and incremental depreciation were added to book profit. Deduction under section 10A was computed before set-off of brought-forward losses and unabsorbed depreciation, telecommunication expenses were excluded from both export and total turnover, mobile phones were treated as capital assets, and interest on delayed TDS payment was allowed as deductible. en-us Wed, 05 Apr 2017 00:00:00 +0530 Thu, 21 Dec 2017 08:15:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=197005 Transfer pricing comparability under internal TNMM requires genuine functional similarity; material differences in technology, brand strength, marketing, procurement, risk profile and R&D intensity justify rejection of segmented comparison. Operating profit for the manufacturing segment must reflect the true character of receipts, so BMSS income was excluded, market promotion fees were included, and other disputed items were remitted for factual verification where their operating nature was unclear. Adjustment could not be confined only to international transactions. For MAT, provision for wealth-tax and incremental depreciation were added to book profit. Deduction under section 10A was computed before set-off of brought-forward losses and unabsorbed depreciation, telecommunication expenses were excluded from both export and total turnover, mobile phones were treated as capital assets, and interest on delayed TDS payment was allowed as deductible. Case-Laws Income Tax Wed, 05 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=197005