https://www.taxtmi.com/caselaws?id=784180 The dominant issue was whether the impugned comparables could be retained for TP adjustment despite functional dissimilarity and failing the export turnover filter. The HC held that the DRP correctly applied the functional comparability test, finding the selected companies engaged in activities beyond the assessee's export service business, and also correctly applied the 75% export turnover criterion, noting one comparable had only 49% export income against the tested party's 100% export profile; the ITAT's acceptance of these findings raised no substantial question of law as they were pure findings of fact. The appeal was dismissed on merits. en-us Wed, 24 Dec 2025 00:00:00 +0530 Tue, 30 Dec 2025 09:29:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784180 The dominant issue was whether the impugned comparables could be retained for TP adjustment despite functional dissimilarity and failing the export turnover filter. The HC held that the DRP correctly applied the functional comparability test, finding the selected companies engaged in activities beyond the assessee's export service business, and also correctly applied the 75% export turnover criterion, noting one comparable had only 49% export income against the tested party's 100% export profile; the ITAT's acceptance of these findings raised no substantial question of law as they were pure findings of fact. The appeal was dismissed on merits. Case-Laws Income Tax Wed, 24 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784180