https://www.taxtmi.com/caselaws?id=280431 Transfer pricing comparables must be functionally similar and supported by disclosed reasoning; unrelated businesses such as engineering, testing, foreign exchange, travel, or container freight services cannot be introduced without a clear basis. On the facts described, exclusion of the impugned comparables brought the assessee's margin within the permissible range, so the transfer pricing adjustment was deleted. The text also notes that an Assessing Officer must implement a binding Dispute Resolution Panel direction allowing deduction under section 80G, and failure to do so is not justified. The officer was directed to pass the consequential order within the stated time. en-us Tue, 12 Apr 2016 00:00:00 +0530 Sun, 05 May 2019 08:43:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280431 Transfer pricing comparables must be functionally similar and supported by disclosed reasoning; unrelated businesses such as engineering, testing, foreign exchange, travel, or container freight services cannot be introduced without a clear basis. On the facts described, exclusion of the impugned comparables brought the assessee's margin within the permissible range, so the transfer pricing adjustment was deleted. The text also notes that an Assessing Officer must implement a binding Dispute Resolution Panel direction allowing deduction under section 80G, and failure to do so is not justified. The officer was directed to pass the consequential order within the stated time. Case-Laws Income Tax Tue, 12 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280431