https://www.taxtmi.com/caselaws?id=296680 In transfer-pricing comparability analysis, a company cannot be rejected merely because it follows a different accounting year if audited data is available and no real disqualifying factor or extraordinary event is shown. A large brand-driven company with materially different scale, assets, turnover and market position is not a proper comparable to a captive service provider and may be excluded despite earlier inclusion in documentation. Provision for doubtful debts was treated as operating in nature for margin recomputation, and a claim of double deduction of foreign exchange loss was restored for factual verification and fresh computation. The overall adjustment was therefore only partly sustained, with comparables and margins requiring reworking. en-us Mon, 22 Jun 2020 00:00:00 +0530 Tue, 03 Aug 2021 09:11:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296680 In transfer-pricing comparability analysis, a company cannot be rejected merely because it follows a different accounting year if audited data is available and no real disqualifying factor or extraordinary event is shown. A large brand-driven company with materially different scale, assets, turnover and market position is not a proper comparable to a captive service provider and may be excluded despite earlier inclusion in documentation. Provision for doubtful debts was treated as operating in nature for margin recomputation, and a claim of double deduction of foreign exchange loss was restored for factual verification and fresh computation. The overall adjustment was therefore only partly sustained, with comparables and margins requiring reworking. Case-Laws Income Tax Mon, 22 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296680