https://www.taxtmi.com/caselaws?id=763224 ITAT-BANGALORE held that comparables with turnover exceeding Rs.200 crore should be excluded from ALP computation after verification by the AO/TPO; two identified comparables were excluded as functionally dissimilar, while one comparable was retained as functionally similar despite reporting a loss. The tribunal set aside the working-capital adjustment issue to the AO/TPO for verification and fresh adjudication, noting the assessee's burden to produce supporting records. Royalty payments were held to be revenue in nature (not capital). The AO was directed to recompute interest under sections 234D and 244A in accordance with law. en-us Tue, 20 Aug 2024 00:00:00 +0530 Fri, 29 Aug 2025 14:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763224 ITAT-BANGALORE held that comparables with turnover exceeding Rs.200 crore should be excluded from ALP computation after verification by the AO/TPO; two identified comparables were excluded as functionally dissimilar, while one comparable was retained as functionally similar despite reporting a loss. The tribunal set aside the working-capital adjustment issue to the AO/TPO for verification and fresh adjudication, noting the assessee's burden to produce supporting records. Royalty payments were held to be revenue in nature (not capital). The AO was directed to recompute interest under sections 234D and 244A in accordance with law. Case-Laws Income Tax Tue, 20 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763224