https://www.taxtmi.com/caselaws?id=312272 Under TNMM, Concord United Pvt. Ltd. and Sharpline Automation Pvt. Ltd. were found not functionally comparable because their business profiles, products, functions and segment information did not match the assessee's manufacturing operations, so they were excluded. The treatment of provision for expected loss and its reversal required consistent computation of operating margins, and the matter was remitted for fresh examination. Reimbursement of expat salary cost was treated as a verification issue: a pure salary reimbursement without an income element or make-available component was not to be disallowed mechanically for alleged TDS failure, so the authorities were directed to recheck the documents. TDS credit was also to be verified and allowed by the Assessing Officer. en-us Tue, 14 Feb 2023 00:00:00 +0530 Fri, 09 Feb 2024 18:27:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312272 Under TNMM, Concord United Pvt. Ltd. and Sharpline Automation Pvt. Ltd. were found not functionally comparable because their business profiles, products, functions and segment information did not match the assessee's manufacturing operations, so they were excluded. The treatment of provision for expected loss and its reversal required consistent computation of operating margins, and the matter was remitted for fresh examination. Reimbursement of expat salary cost was treated as a verification issue: a pure salary reimbursement without an income element or make-available component was not to be disallowed mechanically for alleged TDS failure, so the authorities were directed to recheck the documents. TDS credit was also to be verified and allowed by the Assessing Officer. Case-Laws Income Tax Tue, 14 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312272