https://www.taxtmi.com/caselaws?id=791348 In transfer pricing matters, comparability must be assessed on functional similarity under the FAR framework, and a comparable crossing the applied related party transaction filter cannot be retained; Liquidhub Analytics Private Limited was therefore excluded. Comparables proposed by the assessee may be examined afresh if supported by proper functional and filter-based material, so the matter was restored to the AO/TPO. ESOP cost borne by the AE could not be loaded only on the cost side; corresponding operating revenue had to be recognised for parity. Working capital adjustment required fresh, scientific computation, and notional interest on delayed foreign-currency receivables was sustainable in principle, to be recomputed at LIBOR plus 200 basis points for the actual delay. en-us Wed, 29 Apr 2026 00:00:00 +0530 Sat, 09 May 2026 07:13:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791348 In transfer pricing matters, comparability must be assessed on functional similarity under the FAR framework, and a comparable crossing the applied related party transaction filter cannot be retained; Liquidhub Analytics Private Limited was therefore excluded. Comparables proposed by the assessee may be examined afresh if supported by proper functional and filter-based material, so the matter was restored to the AO/TPO. ESOP cost borne by the AE could not be loaded only on the cost side; corresponding operating revenue had to be recognised for parity. Working capital adjustment required fresh, scientific computation, and notional interest on delayed foreign-currency receivables was sustainable in principle, to be recomputed at LIBOR plus 200 basis points for the actual delay. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791348