https://www.taxtmi.com/caselaws?id=787625 In a transfer-pricing review the tribunal excluded a listed comparable on the ground that functional analysis showed the entity was engaged in manufacturing battery-production machinery and was therefore functionally dissimilar to the assessee, rendering it unsuitable for arm's-length benchmarking; this outcome favoured the assessee. The tribunal also admitted fresh grounds asserting that an excise duty exemption might be a capital-type receipt but directed remand to the assessing officer because the question requires factual verification of scheme eligibility and quantification, so the matter is to be verified and determined by the assessing authority. en-us Fri, 06 Mar 2026 00:00:00 +0530 Tue, 10 Mar 2026 08:51:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787625 In a transfer-pricing review the tribunal excluded a listed comparable on the ground that functional analysis showed the entity was engaged in manufacturing battery-production machinery and was therefore functionally dissimilar to the assessee, rendering it unsuitable for arm's-length benchmarking; this outcome favoured the assessee. The tribunal also admitted fresh grounds asserting that an excise duty exemption might be a capital-type receipt but directed remand to the assessing officer because the question requires factual verification of scheme eligibility and quantification, so the matter is to be verified and determined by the assessing authority. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787625