https://www.taxtmi.com/caselaws?id=791746 Under TNMM, comparability depends primarily on FAR analysis, with the search matrix serving only as a tool; functionally dissimilar companies, entities with high R&D intensity, filter failures, or distorted turnover were excluded, while similar companies were retained. Provision for doubtful debts and routine rates and taxes were treated as operating items, and working capital differences in receivables, payables and inventory were held to warrant adjustment, subject to recomputation. Notional interest on delayed AE receivables was not sustained absent borrowing cost or actual benefit. Royalty and intra-group service charges could not be benchmarked at nil without proper comparables, and the section 40(a)(ia) disallowance failed where the sums were not shown to be TDS-applicable. en-us Wed, 06 May 2026 00:00:00 +0530 Sat, 16 May 2026 09:09:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791746 Under TNMM, comparability depends primarily on FAR analysis, with the search matrix serving only as a tool; functionally dissimilar companies, entities with high R&D intensity, filter failures, or distorted turnover were excluded, while similar companies were retained. Provision for doubtful debts and routine rates and taxes were treated as operating items, and working capital differences in receivables, payables and inventory were held to warrant adjustment, subject to recomputation. Notional interest on delayed AE receivables was not sustained absent borrowing cost or actual benefit. Royalty and intra-group service charges could not be benchmarked at nil without proper comparables, and the section 40(a)(ia) disallowance failed where the sums were not shown to be TDS-applicable. Case-Laws Income Tax Wed, 06 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791746