https://www.taxtmi.com/caselaws?id=468216 In transfer pricing comparability analysis, loss-making companies were held not to be excluded merely for persistent losses if their functional profile remained aligned. Autoline Industries Limited and Automotive Stampings & Assemblies Limited were therefore retained as comparables. By contrast, Gatiman Auto Private Limited was excluded for major turnover disparity and functional mismatch, Bundy India Limited for functional dissimilarity and lack of reliable segmental data, and Brakes India Private Limited for significant functional differences, R&D intensity, scale, and consistency with prior-year treatment. The first appellate authority's comparable selection was sustained in full, and the revenue's challenge failed on all substantive grounds. en-us Thu, 14 Nov 2024 00:00:00 +0530 Thu, 23 Apr 2026 08:54:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468216 In transfer pricing comparability analysis, loss-making companies were held not to be excluded merely for persistent losses if their functional profile remained aligned. Autoline Industries Limited and Automotive Stampings & Assemblies Limited were therefore retained as comparables. By contrast, Gatiman Auto Private Limited was excluded for major turnover disparity and functional mismatch, Bundy India Limited for functional dissimilarity and lack of reliable segmental data, and Brakes India Private Limited for significant functional differences, R&D intensity, scale, and consistency with prior-year treatment. The first appellate authority's comparable selection was sustained in full, and the revenue's challenge failed on all substantive grounds. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468216