https://www.taxtmi.com/caselaws?id=431805 Transfer pricing benchmarking under the transactional net margin method requires functional comparability and reliable segmental results; companies that are functionally dissimilar or whose segmental profitability is distorted by unallocable items may be excluded, and unexplored comparables may be remitted for verification. The assessee was also entitled to verification and grant of TDS credit in accordance with law. Computation of interest under section 244A likewise required fresh verification because it depended on the correct working of the refund amount. The matter therefore resulted in partial relief, with transfer pricing, TDS credit, and interest issues sent back for de novo examination by the lower authority. en-us Wed, 24 Aug 2022 00:00:00 +0530 Tue, 20 Dec 2022 16:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431805 Transfer pricing benchmarking under the transactional net margin method requires functional comparability and reliable segmental results; companies that are functionally dissimilar or whose segmental profitability is distorted by unallocable items may be excluded, and unexplored comparables may be remitted for verification. The assessee was also entitled to verification and grant of TDS credit in accordance with law. Computation of interest under section 244A likewise required fresh verification because it depended on the correct working of the refund amount. The matter therefore resulted in partial relief, with transfer pricing, TDS credit, and interest issues sent back for de novo examination by the lower authority. Case-Laws Income Tax Wed, 24 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431805