https://www.taxtmi.com/caselaws?id=446044 ITAT Chennai upheld TPO's TP adjustment, rejecting appellant's challenges on comparability of Victor Gaskets India Ltd, Banco Gaskets (India) Ltd, Minda Corporation, and Talbros Automotive Components. Court held TNMM method is resistant to product/functional differences and higher margins alone cannot exclude comparables. Rejected multiple year data use, treating foreign exchange loss as non-operating, and working capital/custom duty adjustments due to insufficient evidence. Disallowed warranty expenses as contingent without scientific basis. Remanded Pooja expenses issue for AO re-examination. Dismissed additional grounds petition as factual rather than legal issue. en-us Tue, 31 Oct 2023 00:00:00 +0530 Thu, 23 Nov 2023 11:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446044 ITAT Chennai upheld TPO's TP adjustment, rejecting appellant's challenges on comparability of Victor Gaskets India Ltd, Banco Gaskets (India) Ltd, Minda Corporation, and Talbros Automotive Components. Court held TNMM method is resistant to product/functional differences and higher margins alone cannot exclude comparables. Rejected multiple year data use, treating foreign exchange loss as non-operating, and working capital/custom duty adjustments due to insufficient evidence. Disallowed warranty expenses as contingent without scientific basis. Remanded Pooja expenses issue for AO re-examination. Dismissed additional grounds petition as factual rather than legal issue. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446044