https://www.taxtmi.com/caselaws?id=791012 In transfer pricing analysis, a comparable company is not to be excluded merely because it follows a different financial year if reliable reconstructed financial data can be used to derive its margin, subject to verification. Working capital adjustment cannot be denied on general assumptions; Rule 10B(3) requires a reasoned economic analysis and testing of the adjustment where material differences affect comparability. Overdue trade receivables may be treated as a separate international transaction when delays are abnormal, but the benchmark interest computation and related mapping of credit notes may need fresh examination. Additional claims for foreign tax credit and deduction of foreign tax paid may also be admitted for verification where the computation was not earlier available. en-us Thu, 05 Mar 2026 00:00:00 +0530 Tue, 05 May 2026 09:09:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791012 In transfer pricing analysis, a comparable company is not to be excluded merely because it follows a different financial year if reliable reconstructed financial data can be used to derive its margin, subject to verification. Working capital adjustment cannot be denied on general assumptions; Rule 10B(3) requires a reasoned economic analysis and testing of the adjustment where material differences affect comparability. Overdue trade receivables may be treated as a separate international transaction when delays are abnormal, but the benchmark interest computation and related mapping of credit notes may need fresh examination. Additional claims for foreign tax credit and deduction of foreign tax paid may also be admitted for verification where the computation was not earlier available. Case-Laws Income Tax Thu, 05 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791012