https://www.taxtmi.com/caselaws?id=306329 CTR Manufacturing Industries Ltd. was held not to be a valid transfer pricing comparable because its functional profile differed from the assessee's capacitor and resistor manufacturing segment and no comparable segmental data was available. The Tribunal therefore directed its exclusion from the comparables set. Payments for leased line and related IT infrastructure charges were treated as cost-to-cost reimbursements without markup and, following the assessee's earlier year, were held not to be royalty or any other sum chargeable to tax. As a result, no tax deduction was required under section 195 and the corresponding disallowance under section 40(a)(i) was deleted. en-us Tue, 19 Jan 2021 00:00:00 +0530 Mon, 23 Jan 2023 11:04:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306329 CTR Manufacturing Industries Ltd. was held not to be a valid transfer pricing comparable because its functional profile differed from the assessee's capacitor and resistor manufacturing segment and no comparable segmental data was available. The Tribunal therefore directed its exclusion from the comparables set. Payments for leased line and related IT infrastructure charges were treated as cost-to-cost reimbursements without markup and, following the assessee's earlier year, were held not to be royalty or any other sum chargeable to tax. As a result, no tax deduction was required under section 195 and the corresponding disallowance under section 40(a)(i) was deleted. Case-Laws Income Tax Tue, 19 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306329