https://www.taxtmi.com/caselaws?id=425851 Transfer pricing comparability under Chapter X requires uncontrolled transactions to be materially similar, and Rule 10B(2) comparability criteria remain applicable even when TNMM is used. A proposed comparable must satisfy the relevant functional and economic filters; on the facts, Excel Infoways Ltd. failed the 75% service revenue filter applied by the TPO and also did not meet the diminishing revenue filter reflected in its financial data. The company was therefore treated as not comparable for arm's length price determination, and no substantial question of law arose. en-us Wed, 29 Jun 2022 00:00:00 +0530 Tue, 02 Aug 2022 09:45:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=425851 Transfer pricing comparability under Chapter X requires uncontrolled transactions to be materially similar, and Rule 10B(2) comparability criteria remain applicable even when TNMM is used. A proposed comparable must satisfy the relevant functional and economic filters; on the facts, Excel Infoways Ltd. failed the 75% service revenue filter applied by the TPO and also did not meet the diminishing revenue filter reflected in its financial data. The company was therefore treated as not comparable for arm's length price determination, and no substantial question of law arose. Case-Laws Income Tax Wed, 29 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=425851