https://www.taxtmi.com/caselaws?id=793217 Comparability under TNMM must rest on reliable, consistent financial data: MSL Driveline Systems Ltd. was excluded because its related party disclosures were contradictory and the RPT filter was breached. Bharat Gears Ltd. and JMT Auto Ltd. could not be excluded as persistent loss-makers on a profit-before-tax basis, since TNMM focuses on operating profit and both had profits in one relevant year. Depreciation differences may require adjustment where asset base and depreciation policy materially distort margins, so the issue was remitted for verification. Transfer pricing adjustment must be confined to international transactions with associated enterprises, and adjustments under section 143(1) could not survive after notice under section 143(2) had been issued. en-us Wed, 06 May 2026 00:00:00 +0530 Thu, 11 Jun 2026 08:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793217 Comparability under TNMM must rest on reliable, consistent financial data: MSL Driveline Systems Ltd. was excluded because its related party disclosures were contradictory and the RPT filter was breached. Bharat Gears Ltd. and JMT Auto Ltd. could not be excluded as persistent loss-makers on a profit-before-tax basis, since TNMM focuses on operating profit and both had profits in one relevant year. Depreciation differences may require adjustment where asset base and depreciation policy materially distort margins, so the issue was remitted for verification. Transfer pricing adjustment must be confined to international transactions with associated enterprises, and adjustments under section 143(1) could not survive after notice under section 143(2) had been issued. Case-Laws Income Tax Wed, 06 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793217