https://www.taxtmi.com/caselaws?id=775613 The ITAT Delhi held that several companies selected as comparables by the TPO were inappropriate due to functional dissimilarity, differences in core versus non-core auto component manufacturing, and divergent business profiles including R&D and export activities. Companies manufacturing core auto components or having diversified operations unrelated to the assessee's two-wheeler non-core component manufacturing were excluded. However, Auto Line Industries was retained as a comparable despite losses, as it had reported profits in one of three years and shared a similar functional profile. The appeal was allowed, directing the exclusion of unsuitable comparables and affirming that loss-making companies cannot be excluded solely on that basis when functional similarity exists. en-us Mon, 21 Jul 2025 00:00:00 +0530 Mon, 28 Jul 2025 08:27:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775613 The ITAT Delhi held that several companies selected as comparables by the TPO were inappropriate due to functional dissimilarity, differences in core versus non-core auto component manufacturing, and divergent business profiles including R&D and export activities. Companies manufacturing core auto components or having diversified operations unrelated to the assessee's two-wheeler non-core component manufacturing were excluded. However, Auto Line Industries was retained as a comparable despite losses, as it had reported profits in one of three years and shared a similar functional profile. The appeal was allowed, directing the exclusion of unsuitable comparables and affirming that loss-making companies cannot be excluded solely on that basis when functional similarity exists. Case-Laws Income Tax Mon, 21 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775613