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    <title>2026 (4) TMI 1779 - ITAT BANGALORE</title>
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    <description>Transfer pricing comparability under the transactional net margin method depends on functional similarity and filter compliance. One company was correctly retained as functionally comparable, while another was not excluded merely because of share capital infusion, since that did not by itself establish an extraordinary event; its margin computation was however directed to be verified. A company engaged in trading medical equipment and diagnostic kits was also held comparable and its exclusion was declined. For another company, related party transaction filter compliance and margin computation were left for verification by the Assessing Officer, and the requested inclusion of an additional company was likewise directed to be examined for filter compliance.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790710</link>
      <description>Transfer pricing comparability under the transactional net margin method depends on functional similarity and filter compliance. One company was correctly retained as functionally comparable, while another was not excluded merely because of share capital infusion, since that did not by itself establish an extraordinary event; its margin computation was however directed to be verified. A company engaged in trading medical equipment and diagnostic kits was also held comparable and its exclusion was declined. For another company, related party transaction filter compliance and margin computation were left for verification by the Assessing Officer, and the requested inclusion of an additional company was likewise directed to be examined for filter compliance.</description>
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