https://www.taxtmi.com/caselaws?id=468348 Transfer pricing comparability under Rule 10B(2)(d) and Rule 10B(3) requires market conditions to be weighed realistically, including geographical location, market size, regulatory environment and other economic factors. Where an Indian tested party bears substantial customs duty but foreign comparables operate in a market with nil or negligible customs duty, that disparity can materially distort gross and operating margins. In such circumstances, a reasonable quantitative adjustment is justified so the comparables remain reliable and the arm's length analysis reflects actual profitability differences. The customs duty adjustment was therefore upheld as necessary to make the comparison meaningful. en-us Tue, 30 Jul 2024 00:00:00 +0530 Wed, 29 Apr 2026 18:58:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468348 Transfer pricing comparability under Rule 10B(2)(d) and Rule 10B(3) requires market conditions to be weighed realistically, including geographical location, market size, regulatory environment and other economic factors. Where an Indian tested party bears substantial customs duty but foreign comparables operate in a market with nil or negligible customs duty, that disparity can materially distort gross and operating margins. In such circumstances, a reasonable quantitative adjustment is justified so the comparables remain reliable and the arm's length analysis reflects actual profitability differences. The customs duty adjustment was therefore upheld as necessary to make the comparison meaningful. Case-Laws Income Tax Tue, 30 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468348