https://www.taxtmi.com/caselaws?id=468388 Transfer pricing comparability analysis requires material differences affecting margins to be neutralised through reasonably accurate adjustments. Foreign exchange loss on forward contracts was treated as a factor that may be non-operating for margin computation, and the tested party figures could be adjusted where comparable data is unavailable. Comparable selection must reflect functional similarity and turnover filter discipline, so materially higher-turnover software development and IT enabled services companies may be excluded. Working capital adjustment forms part of the arm's length analysis and may be recomputed using actual comparable data, with necessary details gathered if required. en-us Wed, 13 Apr 2022 00:00:00 +0530 Fri, 10 Jul 2026 17:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468388 Transfer pricing comparability analysis requires material differences affecting margins to be neutralised through reasonably accurate adjustments. Foreign exchange loss on forward contracts was treated as a factor that may be non-operating for margin computation, and the tested party figures could be adjusted where comparable data is unavailable. Comparable selection must reflect functional similarity and turnover filter discipline, so materially higher-turnover software development and IT enabled services companies may be excluded. Working capital adjustment forms part of the arm's length analysis and may be recomputed using actual comparable data, with necessary details gathered if required. Case-Laws Income Tax Wed, 13 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468388