https://www.taxtmi.com/caselaws?id=467754 Functional similarity and reliable segmental information were treated as decisive in transfer pricing comparability analysis, and entities with dissimilar business profiles, unavailable segmental data, failing related-party filters or otherwise unsuitable on the facts were excluded. Different financial year ends did not by itself require exclusion where comparison remained reliable, while persistent losses were not an automatic disqualifier unless the overall comparability exercise so indicated. The transfer pricing adjustment was therefore to be recomputed after revising the comparable set, and entitlement to the +/-5% range under the proviso to section 92C(2) was to be examined on that recomputed basis. en-us Fri, 03 Mar 2023 00:00:00 +0530 Wed, 01 Apr 2026 16:31:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467754 Functional similarity and reliable segmental information were treated as decisive in transfer pricing comparability analysis, and entities with dissimilar business profiles, unavailable segmental data, failing related-party filters or otherwise unsuitable on the facts were excluded. Different financial year ends did not by itself require exclusion where comparison remained reliable, while persistent losses were not an automatic disqualifier unless the overall comparability exercise so indicated. The transfer pricing adjustment was therefore to be recomputed after revising the comparable set, and entitlement to the +/-5% range under the proviso to section 92C(2) was to be examined on that recomputed basis. Case-Laws Income Tax Fri, 03 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467754