https://www.taxtmi.com/caselaws?id=783955 The dominant issue was the validity of the TPO's exclusion of four comparables selected in the taxpayer's TPSR for determining the ALP. Since the TPO rejected those comparables without recording reasons and merely dismissed the taxpayer's detailed submissions as "not acceptable," the rejection was held arbitrary; the AO/TPO was directed to include all four comparables in the final set. A second issue concerned denial of working-capital adjustment. Applying Rule 10B(1)(e)(iii) and HC authority, the Tribunal held that such adjustment is mandated where relevant; the AO/TPO was directed to grant working-capital adjustment on recomputation, subject to the taxpayer furnishing requisite details, and the ground was allowed for statistical purposes. en-us Fri, 21 Nov 2025 00:00:00 +0530 Fri, 26 Dec 2025 07:18:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783955 The dominant issue was the validity of the TPO's exclusion of four comparables selected in the taxpayer's TPSR for determining the ALP. Since the TPO rejected those comparables without recording reasons and merely dismissed the taxpayer's detailed submissions as "not acceptable," the rejection was held arbitrary; the AO/TPO was directed to include all four comparables in the final set. A second issue concerned denial of working-capital adjustment. Applying Rule 10B(1)(e)(iii) and HC authority, the Tribunal held that such adjustment is mandated where relevant; the AO/TPO was directed to grant working-capital adjustment on recomputation, subject to the taxpayer furnishing requisite details, and the ground was allowed for statistical purposes. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783955