https://www.taxtmi.com/caselaws?id=789036 A transfer pricing comparable already accepted by the TPO and retained by the first appellate authority could not be challenged by the Revenue for the first time before the Tribunal on the ground of functional dissimilarity. The comparable had formed part of the assessee's transfer pricing study and its segmental results were used for benchmarking the engineering, technical and inspection segment. The Tribunal held that the Revenue could not agitate exclusion at the second appellate stage when the issue had not been raised before the lower appellate authority. The ground seeking exclusion of Onward Technologies Ltd. was rejected, and the issue was decided in favour of the assessee. en-us Wed, 25 Mar 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789036 A transfer pricing comparable already accepted by the TPO and retained by the first appellate authority could not be challenged by the Revenue for the first time before the Tribunal on the ground of functional dissimilarity. The comparable had formed part of the assessee's transfer pricing study and its segmental results were used for benchmarking the engineering, technical and inspection segment. The Tribunal held that the Revenue could not agitate exclusion at the second appellate stage when the issue had not been raised before the lower appellate authority. The ground seeking exclusion of Onward Technologies Ltd. was rejected, and the issue was decided in favour of the assessee. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789036