https://www.taxtmi.com/caselaws?id=790696 Persistent loss filter cannot justify exclusion of a comparable unless it shows losses throughout the relevant successive years; comparables lacking functional similarity, similar turnover, segmental data, or free from extraordinary events may be excluded instead, and the two loss-year comparables were directed to be included while dissimilar comparables were excluded. Foreign exchange fluctuation gain arising from realization of export-service receivables is operating income for transfer pricing purposes and was so treated in computing the profit level indicator. Risk adjustment was not decided on merits and was remitted for fresh examination. Credit for self-assessment tax and tax collected at source was to be granted subject to verification. en-us Wed, 18 Mar 2026 00:00:00 +0530 Wed, 29 Apr 2026 08:16:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790696 Persistent loss filter cannot justify exclusion of a comparable unless it shows losses throughout the relevant successive years; comparables lacking functional similarity, similar turnover, segmental data, or free from extraordinary events may be excluded instead, and the two loss-year comparables were directed to be included while dissimilar comparables were excluded. Foreign exchange fluctuation gain arising from realization of export-service receivables is operating income for transfer pricing purposes and was so treated in computing the profit level indicator. Risk adjustment was not decided on merits and was remitted for fresh examination. Credit for self-assessment tax and tax collected at source was to be granted subject to verification. Case-Laws Income Tax Wed, 18 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790696