https://www.taxtmi.com/caselaws?id=308285 The Tribunal partially allowed the appeal, directing the Transfer Pricing Officer to recompute the margin based on exclusions and reconsiderations of comparables. Emphasizing the importance of a fair comparability analysis, adjustments for risk profiles, and pass-through costs, the Tribunal focused on functional similarities and differences. Notably, certain comparables were excluded due to functional dissimilarities, while adjustments for risk profiles were deemed necessary. The Tribunal highlighted the need for accuracy in comparability analysis and directed the exclusion of certain companies for a more precise determination of the Arm's Length Price. en-us Fri, 02 Aug 2019 00:00:00 +0530 Tue, 13 Jun 2023 20:48:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308285 The Tribunal partially allowed the appeal, directing the Transfer Pricing Officer to recompute the margin based on exclusions and reconsiderations of comparables. Emphasizing the importance of a fair comparability analysis, adjustments for risk profiles, and pass-through costs, the Tribunal focused on functional similarities and differences. Notably, certain comparables were excluded due to functional dissimilarities, while adjustments for risk profiles were deemed necessary. The Tribunal highlighted the need for accuracy in comparability analysis and directed the exclusion of certain companies for a more precise determination of the Arm's Length Price. Case-Laws Income Tax Fri, 02 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308285