https://www.taxtmi.com/caselaws?id=793108 Transfer pricing comparability under Rule 10B(2)(d) requires similarity in functional profile, customer base, and market conditions; retail and after-sales businesses were held unsuitable comparables for a wholesale trading segment to OEMs, and exclusion of those comparables removed the basis for adjustment. A disallowance under section 40(a)(ia) was also considered, but revised audit material and a deductee certificate required further factual verification before any final view could be taken, so the matter was restored for fresh adjudication. en-us Wed, 20 May 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793108 Transfer pricing comparability under Rule 10B(2)(d) requires similarity in functional profile, customer base, and market conditions; retail and after-sales businesses were held unsuitable comparables for a wholesale trading segment to OEMs, and exclusion of those comparables removed the basis for adjustment. A disallowance under section 40(a)(ia) was also considered, but revised audit material and a deductee certificate required further factual verification before any final view could be taken, so the matter was restored for fresh adjudication. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793108