https://www.taxtmi.com/caselaws?id=409989 Exclusion of a staffing/recruitment service company as a TP comparable turned on failure of FAR comparability: the Tribunal found absence of segmental financials and functional dissimilarity with the tested party, vitiating the comparability analysis; the disputed comparable was directed to be removed, reducing the TP adjustment. Notional interest on outstanding receivables was held impermissible where the taxpayer was debt-free and funded by own capital; relying on HC precedent affirmed in the taxpayer's own case and noting SC dismissal of the Revenue's SLP, the Tribunal held no statutory basis to impute interest and deleted the adjustment. On income reconciliation, the AO was directed to implement DRP verification directions. Education cess was held deductible as a business expenditure, granting relief. en-us Fri, 09 Jul 2021 00:00:00 +0530 Fri, 09 Jan 2026 12:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409989 Exclusion of a staffing/recruitment service company as a TP comparable turned on failure of FAR comparability: the Tribunal found absence of segmental financials and functional dissimilarity with the tested party, vitiating the comparability analysis; the disputed comparable was directed to be removed, reducing the TP adjustment. Notional interest on outstanding receivables was held impermissible where the taxpayer was debt-free and funded by own capital; relying on HC precedent affirmed in the taxpayer's own case and noting SC dismissal of the Revenue's SLP, the Tribunal held no statutory basis to impute interest and deleted the adjustment. On income reconciliation, the AO was directed to implement DRP verification directions. Education cess was held deductible as a business expenditure, granting relief. Case-Laws Income Tax Fri, 09 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409989