https://www.taxtmi.com/caselaws?id=465732 In determining arm's length price, the Tribunal held that a proposed comparable was functionally dissimilar to the assessee and could not be included; the challenge to its exclusion was rejected. On comparables selection, it held that applying a turnover filter excluding entities with turnover exceeding ?200 crores is a valid comparability criterion; the TPO was directed to exclude such high-turnover comparables and redo the TP analysis, allowing the ground for statistical purposes. On notional interest on delayed receivables, since the payment due date did not fall within the relevant assessment year, no adjustment could be made in that year on the principle that income must be taxed in the correct year; however, for the subsequent year, the TPO was directed to apply 6-month LIBOR plus 300 basis points. en-us Fri, 24 Jan 2025 00:00:00 +0530 Tue, 06 Jan 2026 22:17:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465732 In determining arm's length price, the Tribunal held that a proposed comparable was functionally dissimilar to the assessee and could not be included; the challenge to its exclusion was rejected. On comparables selection, it held that applying a turnover filter excluding entities with turnover exceeding ?200 crores is a valid comparability criterion; the TPO was directed to exclude such high-turnover comparables and redo the TP analysis, allowing the ground for statistical purposes. On notional interest on delayed receivables, since the payment due date did not fall within the relevant assessment year, no adjustment could be made in that year on the principle that income must be taxed in the correct year; however, for the subsequent year, the TPO was directed to apply 6-month LIBOR plus 300 basis points. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465732