https://www.taxtmi.com/caselaws?id=790412 Transfer pricing analysis under the ITAT Delhi approach focuses on functional comparability, working capital adjustment, risk adjustment, multi-year data, and the five per cent tolerance benefit. India Tourism Development Corporation Limited was found not to be a persistent loss-maker and was remanded for fresh examination, Inhouse Production Limited was considered functionally comparable and directed to be included, while Elbit Diagnostics Limited was not accepted as a comparable on the facts. Working capital adjustment was required on the directed methodology, but no separate risk adjustment was granted in the no-risk service model. Current year data was upheld for arm's length price computation, and the five per cent benefit under the amended section 92C(2) framework was denied. en-us Wed, 22 Apr 2026 00:00:00 +0530 Fri, 24 Apr 2026 08:52:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790412 Transfer pricing analysis under the ITAT Delhi approach focuses on functional comparability, working capital adjustment, risk adjustment, multi-year data, and the five per cent tolerance benefit. India Tourism Development Corporation Limited was found not to be a persistent loss-maker and was remanded for fresh examination, Inhouse Production Limited was considered functionally comparable and directed to be included, while Elbit Diagnostics Limited was not accepted as a comparable on the facts. Working capital adjustment was required on the directed methodology, but no separate risk adjustment was granted in the no-risk service model. Current year data was upheld for arm's length price computation, and the five per cent benefit under the amended section 92C(2) framework was denied. Case-Laws Income Tax Wed, 22 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790412