https://www.taxtmi.com/caselaws?id=412038 Transfer pricing comparability must be based on functional similarity, reliable segmental data, and absence of material product-service differences, so companies with mixed business models or unusable segmental results are not reliable comparables, while wrongly excluded comparables may be reinstated. A margin accepted under the Mutual Agreement Procedure for one indistinguishable set of associated enterprise ITES transactions may also apply to another indistinguishable set where no material distinction is shown. Negative working capital adjustment and set-off of brought forward loss require verification in giving effect to the order. For section 10A, items excluded from export turnover must also be excluded from total turnover to preserve parity in the deduction formula. en-us Tue, 03 Aug 2021 00:00:00 +0530 Tue, 07 Sep 2021 16:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412038 Transfer pricing comparability must be based on functional similarity, reliable segmental data, and absence of material product-service differences, so companies with mixed business models or unusable segmental results are not reliable comparables, while wrongly excluded comparables may be reinstated. A margin accepted under the Mutual Agreement Procedure for one indistinguishable set of associated enterprise ITES transactions may also apply to another indistinguishable set where no material distinction is shown. Negative working capital adjustment and set-off of brought forward loss require verification in giving effect to the order. For section 10A, items excluded from export turnover must also be excluded from total turnover to preserve parity in the deduction formula. Case-Laws Income Tax Tue, 03 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412038