https://www.taxtmi.com/caselaws?id=282037 Functional dissimilarity and absence of reliable segmental information justified excluding Accentia Technologies Ltd. and Cat Technologies Ltd. from the transfer pricing comparables, especially where extraordinary acquisitions affected profitability, and the Revenue's challenge failed. For an assessment year preceding Rule 8D, section 14A disallowance had to be made on a reasonable estimate rather than by mechanical application of that rule; the disallowance was accordingly confined to Rs. 30,000. The claim relating to loss on sale of fixed assets required fresh verification from the record, so the matter was remanded for reconsideration after giving the assessee an opportunity of hearing. en-us Mon, 10 Dec 2018 00:00:00 +0530 Fri, 19 Jul 2019 06:27:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=282037 Functional dissimilarity and absence of reliable segmental information justified excluding Accentia Technologies Ltd. and Cat Technologies Ltd. from the transfer pricing comparables, especially where extraordinary acquisitions affected profitability, and the Revenue's challenge failed. For an assessment year preceding Rule 8D, section 14A disallowance had to be made on a reasonable estimate rather than by mechanical application of that rule; the disallowance was accordingly confined to Rs. 30,000. The claim relating to loss on sale of fixed assets required fresh verification from the record, so the matter was remanded for reconsideration after giving the assessee an opportunity of hearing. Case-Laws Income Tax Mon, 10 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=282037