https://www.taxtmi.com/caselaws?id=769339 ITAT Hyderabad rejected the assessee's internal TNMM benchmarking method due to lack of evidence proving functional comparability between associated and non-associated enterprises, geographical differences in transactions, and failure to provide segmental allocation. The tribunal upheld TPO's rejection of the assessee's TP study for non-compliance with Section 92CA(3) and Rule 10B(5), particularly regarding current year data usage. Five companies were excluded from comparables based on turnover filter (10 times upper/lower limit), while three companies were retained as functionally comparable. Eight previously excluded companies were ordered to be included in final comparables, and two companies were directed to be excluded per DRP orders. en-us Thu, 27 Mar 2025 00:00:00 +0530 Thu, 24 Apr 2025 09:13:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769339 ITAT Hyderabad rejected the assessee's internal TNMM benchmarking method due to lack of evidence proving functional comparability between associated and non-associated enterprises, geographical differences in transactions, and failure to provide segmental allocation. The tribunal upheld TPO's rejection of the assessee's TP study for non-compliance with Section 92CA(3) and Rule 10B(5), particularly regarding current year data usage. Five companies were excluded from comparables based on turnover filter (10 times upper/lower limit), while three companies were retained as functionally comparable. Eight previously excluded companies were ordered to be included in final comparables, and two companies were directed to be excluded per DRP orders. Case-Laws Income Tax Thu, 27 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769339