https://www.taxtmi.com/highlights?id=97998 In transfer pricing, broad functional comparability under TNMM was applied: Bright Brothers Ltd. was retained because product differences did not matter where functions were broadly similar, and REIL Electricals India Ltd. was included as functionally similar. Working capital adjustment was treated as a valid claim and was directed to be allowed, subject to the assessee furnishing supporting details and data. On royalty, technical know-how and technical services, the Tribunal upheld deletion of the adjustment because CUP was adopted without comparable uncontrolled data and the principle of consistency supported the assessee, as no adjustment had been made in earlier or subsequent years on the same agreements. en-us Tue, 24 Mar 2026 08:12:27 +0530 Tue, 24 Mar 2026 08:12:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97998 In transfer pricing, broad functional comparability under TNMM was applied: Bright Brothers Ltd. was retained because product differences did not matter where functions were broadly similar, and REIL Electricals India Ltd. was included as functionally similar. Working capital adjustment was treated as a valid claim and was directed to be allowed, subject to the assessee furnishing supporting details and data. On royalty, technical know-how and technical services, the Tribunal upheld deletion of the adjustment because CUP was adopted without comparable uncontrolled data and the principle of consistency supported the assessee, as no adjustment had been made in earlier or subsequent years on the same agreements. Highlights Income Tax Tue, 24 Mar 2026 08:12:27 +0530 https://www.taxtmi.com/highlights?id=97998