https://www.taxtmi.com/caselaws?id=443061 The Tribunal upheld the Dispute Resolution Panel's decision on comparables, emphasizing functional similarity over ownership status. It validated capacity utilization adjustments and dismissed challenges to the assessment order and transfer pricing adjustments. The Tribunal deemed additional companies proposed as comparables as unnecessary due to functional dissimilarity. The Tribunal directed acceptance of the arm's length price if within a tolerance band of comparable companies' margins, otherwise limited adjustments. Both Revenue's appeal and assessee's cross objections were dismissed, affirming the DRP's decisions. en-us Wed, 31 May 2023 00:00:00 +0530 Fri, 15 Sep 2023 08:54:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443061 The Tribunal upheld the Dispute Resolution Panel's decision on comparables, emphasizing functional similarity over ownership status. It validated capacity utilization adjustments and dismissed challenges to the assessment order and transfer pricing adjustments. The Tribunal deemed additional companies proposed as comparables as unnecessary due to functional dissimilarity. The Tribunal directed acceptance of the arm's length price if within a tolerance band of comparable companies' margins, otherwise limited adjustments. Both Revenue's appeal and assessee's cross objections were dismissed, affirming the DRP's decisions. Case-Laws Income Tax Wed, 31 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443061