https://www.taxtmi.com/highlights?id=99279 Under Rule 10B, uncontrolled comparables are usable only where material differences do not affect price, cost or profit, or where reasonably accurate adjustments remove their effect. Because the assessee's purchases were largely imported and bore substantial import duty, while the comparables had negligible import content, the duty element materially distorted the resale price method comparison. The Tribunal therefore directed exclusion of import duty from operating cost when computing PLI and ALP, following the Swatch Group principle. It also allowed working capital adjustment, subject to the assessee furnishing necessary details before the TPO. The penalty ground was treated as premature, and the appeal was partly allowed. en-us Wed, 29 Apr 2026 08:16:36 +0530 Wed, 29 Apr 2026 08:16:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99279 Under Rule 10B, uncontrolled comparables are usable only where material differences do not affect price, cost or profit, or where reasonably accurate adjustments remove their effect. Because the assessee's purchases were largely imported and bore substantial import duty, while the comparables had negligible import content, the duty element materially distorted the resale price method comparison. The Tribunal therefore directed exclusion of import duty from operating cost when computing PLI and ALP, following the Swatch Group principle. It also allowed working capital adjustment, subject to the assessee furnishing necessary details before the TPO. The penalty ground was treated as premature, and the appeal was partly allowed. Highlights Income Tax Wed, 29 Apr 2026 08:16:36 +0530 https://www.taxtmi.com/highlights?id=99279