https://www.taxtmi.com/caselaws?id=790695 In transfer pricing benchmarking under the transactional net margin method, comparables must be functionally similar to the assessee and satisfy the applied filters; companies engaged in specialised R&D or materially different activities, or failing related party, employee cost or service income filters, are to be excluded. The transfer pricing adjustment was therefore not sustainable. The final assessment order under section 144C(13) had to be passed within the prescribed one-month period after receipt of DRP directions; as it was issued beyond that limit, it was held barred by limitation and quashed. 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=790695 In transfer pricing benchmarking under the transactional net margin method, comparables must be functionally similar to the assessee and satisfy the applied filters; companies engaged in specialised R&D or materially different activities, or failing related party, employee cost or service income filters, are to be excluded. The transfer pricing adjustment was therefore not sustainable. The final assessment order under section 144C(13) had to be passed within the prescribed one-month period after receipt of DRP directions; as it was issued beyond that limit, it was held barred by limitation and quashed. Case-Laws Income Tax Wed, 18 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790695