https://www.taxtmi.com/caselaws?id=793105 In transfer pricing analysis, a predominantly trading healthcare segment could not be compared with predominantly manufacturing companies where the functional, asset and risk profiles materially differed, so Poly Medicure Ltd. and Opto Circuits (I) Ltd. were rightly excluded as comparables. By contrast, IT support service payments were accepted because the same arrangement had been allowed in an earlier year on identical facts, only maintenance charges for existing infrastructure were paid, and the services were found to have been rendered; the arm's length value could not be treated as nil. The first appellate relief on both points was sustained. en-us Mon, 18 May 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793105 In transfer pricing analysis, a predominantly trading healthcare segment could not be compared with predominantly manufacturing companies where the functional, asset and risk profiles materially differed, so Poly Medicure Ltd. and Opto Circuits (I) Ltd. were rightly excluded as comparables. By contrast, IT support service payments were accepted because the same arrangement had been allowed in an earlier year on identical facts, only maintenance charges for existing infrastructure were paid, and the services were found to have been rendered; the arm's length value could not be treated as nil. The first appellate relief on both points was sustained. Case-Laws Income Tax Mon, 18 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793105