https://www.taxtmi.com/caselaws?id=757773 Current-year data is the general basis for transfer pricing comparability under Rule 10B, and prior-year data can be used only when its conditions are shown; the rejection of the transfer pricing study was therefore upheld. In the manufacturing segment, functional comparability, product profile, raw material dependence, related party transactions, and filter-based objections led to partial rejection and remand of comparables, so the adjustment was only partly sustainable. The ITES adjustment based on a MAP resolution required FAR verification for uncovered transactions and was remanded. Jigs and fixtures were treated as capital outlay with depreciation as the proper allowance, so the revenue write-off was disallowed. Working capital adjustment also required verification and was remanded. en-us Mon, 10 Jun 2024 00:00:00 +0530 Sat, 31 Aug 2024 11:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757773 Current-year data is the general basis for transfer pricing comparability under Rule 10B, and prior-year data can be used only when its conditions are shown; the rejection of the transfer pricing study was therefore upheld. In the manufacturing segment, functional comparability, product profile, raw material dependence, related party transactions, and filter-based objections led to partial rejection and remand of comparables, so the adjustment was only partly sustainable. The ITES adjustment based on a MAP resolution required FAR verification for uncovered transactions and was remanded. Jigs and fixtures were treated as capital outlay with depreciation as the proper allowance, so the revenue write-off was disallowed. Working capital adjustment also required verification and was remanded. Case-Laws Income Tax Mon, 10 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757773