https://www.taxtmi.com/caselaws?id=366688 The discussion addresses transfer pricing and deduction issues arising in assessment. A comparable selected by the TPO was found not to prima facie satisfy the applied revenue-mix filter, so its inclusion required fresh examination on the correct facts. The assessee's alternative claim for deduction under section 10A could not be ignored after denial of section 10B relief, because the claim had been raised but not examined and needed verification against the statutory conditions. Premium on a forward exchange contract also required reconsideration, as its treatment in operating profit margin depended on whether it arose in the normal course of export-related business and hedging activity. en-us Fri, 07 Sep 2018 00:00:00 +0530 Sat, 08 Sep 2018 08:09:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=366688 The discussion addresses transfer pricing and deduction issues arising in assessment. A comparable selected by the TPO was found not to prima facie satisfy the applied revenue-mix filter, so its inclusion required fresh examination on the correct facts. The assessee's alternative claim for deduction under section 10A could not be ignored after denial of section 10B relief, because the claim had been raised but not examined and needed verification against the statutory conditions. Premium on a forward exchange contract also required reconsideration, as its treatment in operating profit margin depended on whether it arose in the normal course of export-related business and hedging activity. Case-Laws Income Tax Fri, 07 Sep 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=366688