https://www.taxtmi.com/caselaws?id=461355 The ITAT Delhi partially allowed the assessee's appeal in a transfer pricing matter. The tribunal excluded a comparable company from the trading segment analysis, ruling that different product ranges cannot satisfy the functional, asset, and risk comparability test. Regarding capital adjustment methodology, the tribunal held that base rate should be applied instead of prime lending rate, citing RBI guidelines that established the base rate system for enhanced transparency in lending rates and better monetary policy transmission assessment. en-us Thu, 11 Nov 2021 00:00:00 +0530 Tue, 01 Apr 2025 11:42:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461355 The ITAT Delhi partially allowed the assessee's appeal in a transfer pricing matter. The tribunal excluded a comparable company from the trading segment analysis, ruling that different product ranges cannot satisfy the functional, asset, and risk comparability test. Regarding capital adjustment methodology, the tribunal held that base rate should be applied instead of prime lending rate, citing RBI guidelines that established the base rate system for enhanced transparency in lending rates and better monetary policy transmission assessment. Case-Laws Income Tax Thu, 11 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461355