https://www.taxtmi.com/caselaws?id=286633 Transfer pricing analysis requires functional comparability supported by evidence: a company is not excluded merely for introducing a new product line, incurring start-up costs, or undergoing amalgamation unless those factors materially distort comparability, and foreign exchange gain or loss arising from business transactions or year-end restatement may be excluded from operating income where it does not affect the underlying operating profile. A different accounting year can justify exclusion of a comparable if the period difference is not properly reconciled. Related party transaction filters, fresh comparables, interest expenditure exclusions, working capital adjustment, and idle capacity adjustment all depend on substantiated functional and factual material. en-us Wed, 22 Feb 2017 00:00:00 +0530 Wed, 15 Apr 2020 16:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286633 Transfer pricing analysis requires functional comparability supported by evidence: a company is not excluded merely for introducing a new product line, incurring start-up costs, or undergoing amalgamation unless those factors materially distort comparability, and foreign exchange gain or loss arising from business transactions or year-end restatement may be excluded from operating income where it does not affect the underlying operating profile. A different accounting year can justify exclusion of a comparable if the period difference is not properly reconciled. Related party transaction filters, fresh comparables, interest expenditure exclusions, working capital adjustment, and idle capacity adjustment all depend on substantiated functional and factual material. Case-Laws Income Tax Wed, 22 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286633