https://www.taxtmi.com/highlights?id=99390 Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration. en-us Sat, 02 May 2026 07:40:45 +0530 Sat, 02 May 2026 07:40:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99390 Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration. Highlights Income Tax Sat, 02 May 2026 07:40:45 +0530 https://www.taxtmi.com/highlights?id=99390