https://www.taxtmi.com/caselaws?id=785620 Transfer pricing benchmarking requires comparables to be tested for functional similarity and, where available, reliable segmental data; one comparable was remanded for segment review, another for examination on its ARMS segment, a third was rejected in line with the earlier year, and a newly disputed comparable was sent back for full-profile scrutiny. Risk adjustment was not finally quantified and was remanded for fresh determination on proof of risk differences, while working capital adjustment was to be allowed under the DRP's methodology. Bank charges and provision for doubtful debts were treated as operating expenses for margin computation, requiring recomputation. A Rule 27 application based on an adjustment not arising from the assessment order was held not maintainable. en-us Fri, 23 Jan 2026 00:00:00 +0530 Wed, 28 Jan 2026 07:26:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785620 Transfer pricing benchmarking requires comparables to be tested for functional similarity and, where available, reliable segmental data; one comparable was remanded for segment review, another for examination on its ARMS segment, a third was rejected in line with the earlier year, and a newly disputed comparable was sent back for full-profile scrutiny. Risk adjustment was not finally quantified and was remanded for fresh determination on proof of risk differences, while working capital adjustment was to be allowed under the DRP's methodology. Bank charges and provision for doubtful debts were treated as operating expenses for margin computation, requiring recomputation. A Rule 27 application based on an adjustment not arising from the assessment order was held not maintainable. Case-Laws Income Tax Fri, 23 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785620