https://www.taxtmi.com/caselaws?id=410055 In transfer pricing comparability analysis, an export sales filter excluding companies with less than 75% export revenue was treated as valid where the tested party was a low-risk captive service provider mainly serving foreign associated enterprises. A related party transaction filter excluding companies with more than 25% controlled dealings was also upheld because substantial related-party transactions can distort market-driven margins. However, persistent loss-making companies could not be rejected mechanically on the basis of a single year of loss, especially where initial set-up costs or other abnormal factors may explain the result; that filter was not sustained. The matter was remitted for recomputation of the transfer pricing margin on these findings. en-us Tue, 20 Jul 2021 00:00:00 +0530 Fri, 23 Jul 2021 08:58:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=410055 In transfer pricing comparability analysis, an export sales filter excluding companies with less than 75% export revenue was treated as valid where the tested party was a low-risk captive service provider mainly serving foreign associated enterprises. A related party transaction filter excluding companies with more than 25% controlled dealings was also upheld because substantial related-party transactions can distort market-driven margins. However, persistent loss-making companies could not be rejected mechanically on the basis of a single year of loss, especially where initial set-up costs or other abnormal factors may explain the result; that filter was not sustained. The matter was remitted for recomputation of the transfer pricing margin on these findings. Case-Laws Income Tax Tue, 20 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=410055