https://www.taxtmi.com/caselaws?id=436198 Decision addresses transfer pricing comparability selection and arm's length determination. A comparable was excluded because it failed the financial year filter and must be removed. Several comparables were found not functionally similar and are directed to be excluded for failing the functionality test. The tribunal upheld application of arm's length margin determination rules given sufficient comparables, rejected the appellant's plea to exclude high-margin companies, and directed the assessing officer/TPO to verify functional similarities of three specified comparables and apply arm's length methods; any found non-functional may be excluded. en-us Wed, 30 Nov 2022 00:00:00 +0530 Wed, 28 Jan 2026 16:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436198 Decision addresses transfer pricing comparability selection and arm's length determination. A comparable was excluded because it failed the financial year filter and must be removed. Several comparables were found not functionally similar and are directed to be excluded for failing the functionality test. The tribunal upheld application of arm's length margin determination rules given sufficient comparables, rejected the appellant's plea to exclude high-margin companies, and directed the assessing officer/TPO to verify functional similarities of three specified comparables and apply arm's length methods; any found non-functional may be excluded. Case-Laws Income Tax Wed, 30 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436198