https://www.taxtmi.com/caselaws?id=787081 Transfer pricing for imported goods must be revisited by including newly available comparables and applying working capital adjustments where verifiable data exists; the TP officer is directed to consider proportional limitation of any TP adjustment to the import-related portion of operating costs. Avantel Ltd. is functionally dissimilar and excluded from the comparable set due to differing business profile and R&D intensity. An interest addition on External Commercial Borrowings is deleted because benchmarking used recognised databases and consistent treatment in prior years precludes arbitrary deviation. The AO/TPO is remitted to give effect to these adjustments after verification of the assessee's data. en-us Fri, 30 Jan 2026 00:00:00 +0530 Thu, 26 Feb 2026 07:35:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787081 Transfer pricing for imported goods must be revisited by including newly available comparables and applying working capital adjustments where verifiable data exists; the TP officer is directed to consider proportional limitation of any TP adjustment to the import-related portion of operating costs. Avantel Ltd. is functionally dissimilar and excluded from the comparable set due to differing business profile and R&D intensity. An interest addition on External Commercial Borrowings is deleted because benchmarking used recognised databases and consistent treatment in prior years precludes arbitrary deviation. The AO/TPO is remitted to give effect to these adjustments after verification of the assessee's data. Case-Laws Income Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787081