https://www.taxtmi.com/caselaws?id=788507 Under TNMM, comparable selection must rest on broad functional similarity, so a company cannot be excluded merely because it also deals in other products if its functions are broadly similar. A company failing the current year data filter is not a valid comparable. Working capital adjustment is a permissible transfer pricing adjustment and may not be denied only because it was not specifically claimed in the original study, provided supporting details are furnished. Royalty, technical know-how and technical assistance fees may not be adjusted under CUP where the agreement and contemporaneous material show receipt of technical support and business benefit, and reliable uncontrolled comparables are absent. en-us Fri, 06 Mar 2026 00:00:00 +0530 Tue, 24 Mar 2026 08:12:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788507 Under TNMM, comparable selection must rest on broad functional similarity, so a company cannot be excluded merely because it also deals in other products if its functions are broadly similar. A company failing the current year data filter is not a valid comparable. Working capital adjustment is a permissible transfer pricing adjustment and may not be denied only because it was not specifically claimed in the original study, provided supporting details are furnished. Royalty, technical know-how and technical assistance fees may not be adjusted under CUP where the agreement and contemporaneous material show receipt of technical support and business benefit, and reliable uncontrolled comparables are absent. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788507