https://www.taxtmi.com/caselaws?id=790692 Transfer pricing benchmarking requires functionally similar comparables with reliable comparability. Excel Infoways Ltd. was excluded because its functional profile and margin behaviour materially differed, while Jindal Intellicom Ltd. was included because it had been accepted in the assessee's earlier year and no change in function was shown for the year under review. Working capital differences that distort comparison must also be neutralised, so working capital adjustment was held allowable in determining the arm's length margin. en-us Wed, 31 Dec 2025 00:00:00 +0530 Tue, 28 Apr 2026 14:07:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790692 Transfer pricing benchmarking requires functionally similar comparables with reliable comparability. Excel Infoways Ltd. was excluded because its functional profile and margin behaviour materially differed, while Jindal Intellicom Ltd. was included because it had been accepted in the assessee's earlier year and no change in function was shown for the year under review. Working capital differences that distort comparison must also be neutralised, so working capital adjustment was held allowable in determining the arm's length margin. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790692