https://www.taxtmi.com/caselaws?id=793110 Transfer pricing comparability filters must be applied at the initial search stage, not introduced after the comparable set has been finalised; a later R&D filter was therefore rejected as inconsistent with the search process. Turnover is also a relevant comparability factor under the transactional net margin method, because scale, market position, economies of scale, assets and risks can materially affect margins. Comparables with substantially higher turnover than a captive service provider were directed to be excluded, and an upper turnover filter of 10 times the tested party's turnover was accepted for recomputation, resulting in partial relief. en-us Mon, 25 May 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793110 Transfer pricing comparability filters must be applied at the initial search stage, not introduced after the comparable set has been finalised; a later R&D filter was therefore rejected as inconsistent with the search process. Turnover is also a relevant comparability factor under the transactional net margin method, because scale, market position, economies of scale, assets and risks can materially affect margins. Comparables with substantially higher turnover than a captive service provider were directed to be excluded, and an upper turnover filter of 10 times the tested party's turnover was accepted for recomputation, resulting in partial relief. Case-Laws Income Tax Mon, 25 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793110