https://www.taxtmi.com/caselaws?id=309796 Transfer pricing scrutiny addressed inclusion of abnormal manufacturing loss in cost for computation of normal gross profit mark-up; tribunal held extraordinary losses cannot be included in PLI unless the assessee proves actual loss with concrete evidence and remitted the issue to TPO/AO for verification of quantity, price, specification and realizable value. Tribunal directed TPO/AO to reconsider exclusion of a specific comparable if reliable financials are furnished as per DRP directions. Tribunal also held transfer pricing adjustments must be confined to international transactions and applied only to dealings with associated enterprises. en-us Mon, 24 Oct 2016 00:00:00 +0530 Sat, 24 Jan 2026 11:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=309796 Transfer pricing scrutiny addressed inclusion of abnormal manufacturing loss in cost for computation of normal gross profit mark-up; tribunal held extraordinary losses cannot be included in PLI unless the assessee proves actual loss with concrete evidence and remitted the issue to TPO/AO for verification of quantity, price, specification and realizable value. Tribunal directed TPO/AO to reconsider exclusion of a specific comparable if reliable financials are furnished as per DRP directions. Tribunal also held transfer pricing adjustments must be confined to international transactions and applied only to dealings with associated enterprises. Case-Laws Income Tax Mon, 24 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=309796