https://www.taxtmi.com/caselaws?id=771954 ITAT Mumbai ruled in favor of the assessee in a transfer pricing dispute involving international transactions with its Thai AE. The tribunal held that under the Resale Price Method (RPM), functional similarity takes precedence over product similarity in comparability analysis. The court directed the TPO/AO to include five rejected chemical trading companies as valid comparables, finding that operational comparability matters more than product differentiation for benchmarking purposes. The assessee's appeal was allowed, with the tribunal concluding these companies were appropriate comparables for determining arm's length pricing. en-us Fri, 30 May 2025 00:00:00 +0530 Mon, 02 Jun 2025 08:34:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771954 ITAT Mumbai ruled in favor of the assessee in a transfer pricing dispute involving international transactions with its Thai AE. The tribunal held that under the Resale Price Method (RPM), functional similarity takes precedence over product similarity in comparability analysis. The court directed the TPO/AO to include five rejected chemical trading companies as valid comparables, finding that operational comparability matters more than product differentiation for benchmarking purposes. The assessee's appeal was allowed, with the tribunal concluding these companies were appropriate comparables for determining arm's length pricing. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771954