https://www.taxtmi.com/caselaws?id=443351 Transfer pricing comparability must be tested on verifiable functional and segmental data, with annual reports, business profile and reliable public information examined before including or excluding comparables. Persistent loss filters and market-structure differences also require factual verification, so disputed comparables were remanded for fresh examination with only statistical relief to the assessee. Operating margins, working capital adjustments and risk adjustments had to be recomputed where the original basis was flawed, leading to partial relief. Local sourcing support fees were held to be distinct from distribution activity and required separate arm's length benchmarking, so that issue too was sent back for de novo determination. en-us Wed, 26 Jul 2023 00:00:00 +0530 Thu, 21 Sep 2023 08:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443351 Transfer pricing comparability must be tested on verifiable functional and segmental data, with annual reports, business profile and reliable public information examined before including or excluding comparables. Persistent loss filters and market-structure differences also require factual verification, so disputed comparables were remanded for fresh examination with only statistical relief to the assessee. Operating margins, working capital adjustments and risk adjustments had to be recomputed where the original basis was flawed, leading to partial relief. Local sourcing support fees were held to be distinct from distribution activity and required separate arm's length benchmarking, so that issue too was sent back for de novo determination. Case-Laws Income Tax Wed, 26 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443351