https://www.taxtmi.com/caselaws?id=790975 Transfer pricing adjustment requires a proper functional comparability analysis before arm's length price can be affirmed. The record showed a disputed basic profile of the assessee, with one view treating it as a trader in iron ore and coal and another as engaged in production of ferrous products, while the selected comparables were said to have a manufacturing profile. Because the earlier finding on comparability was cryptic and lacked adequate functional and statistical examination, the matter was set aside for fresh consideration by the Dispute Resolution Panel on the assessee's product profile, business activities, and correct selection of comparables. en-us Thu, 30 Apr 2026 00:00:00 +0530 Mon, 04 May 2026 07:57:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790975 Transfer pricing adjustment requires a proper functional comparability analysis before arm's length price can be affirmed. The record showed a disputed basic profile of the assessee, with one view treating it as a trader in iron ore and coal and another as engaged in production of ferrous products, while the selected comparables were said to have a manufacturing profile. Because the earlier finding on comparability was cryptic and lacked adequate functional and statistical examination, the matter was set aside for fresh consideration by the Dispute Resolution Panel on the assessee's product profile, business activities, and correct selection of comparables. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790975