https://www.taxtmi.com/caselaws?id=468643 Delay in filing the appeal was condoned on the basis of sufficient cause, supported by an affidavit and explained by personnel changes and administrative difficulties. On transfer pricing under TNMM, the comparables analysis was sent back for reconsideration: segmental data required fresh examination for one comparable, another comparable warranted merits-based review because segmental data was available, and fall in sales alone was not enough to exclude a comparable absent other material differences. The risk adjustment claim was also restored for fresh consideration because the assessee's lower-risk captive service profile had to be compared against the risk profiles of the comparables. en-us Thu, 11 Nov 2021 00:00:00 +0530 Fri, 15 May 2026 15:30:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468643 Delay in filing the appeal was condoned on the basis of sufficient cause, supported by an affidavit and explained by personnel changes and administrative difficulties. On transfer pricing under TNMM, the comparables analysis was sent back for reconsideration: segmental data required fresh examination for one comparable, another comparable warranted merits-based review because segmental data was available, and fall in sales alone was not enough to exclude a comparable absent other material differences. The risk adjustment claim was also restored for fresh consideration because the assessee's lower-risk captive service profile had to be compared against the risk profiles of the comparables. Case-Laws Income Tax Thu, 11 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468643