https://www.taxtmi.com/caselaws?id=469251 Transfer pricing comparability was tested on a 1:10 turnover filter, which the Tribunal upheld as a valid comparability tool, and Action Construction Equipment Ltd. was directed to be included because it met the filter and no functional dissimilarity was shown. Foreign exchange gain was treated as operating income following the assessee's own case. No disallowance under section 14A read with Rule 8D was sustained because no exempt income was earned, and the Finance Act, 2022 amendment was held not to apply retrospectively. Deduction under section 35(2AB) could not be denied merely for non-issuance of Form 3CL where the R&D facility was approved and the expenditure was otherwise eligible. en-us Mon, 15 May 2023 00:00:00 +0530 Thu, 11 Jun 2026 16:10:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469251 Transfer pricing comparability was tested on a 1:10 turnover filter, which the Tribunal upheld as a valid comparability tool, and Action Construction Equipment Ltd. was directed to be included because it met the filter and no functional dissimilarity was shown. Foreign exchange gain was treated as operating income following the assessee's own case. No disallowance under section 14A read with Rule 8D was sustained because no exempt income was earned, and the Finance Act, 2022 amendment was held not to apply retrospectively. Deduction under section 35(2AB) could not be denied merely for non-issuance of Form 3CL where the R&D facility was approved and the expenditure was otherwise eligible. Case-Laws Income Tax Mon, 15 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469251