https://www.taxtmi.com/caselaws?id=793431 In transfer pricing comparability for auto-component manufacturing, the Safe Harbour definitions of core and non-core auto components may be used as a guiding reference in FAR analysis even where the assessee has not opted into the Safe Harbour regime. The core versus non-core distinction is treated as relevant to product character, pricing dynamics, and functional differences under TNMM. On comparables, helmet manufacturers, a railway-locomotive products manufacturer, and a two-wheeler/commercial vehicle manufacturer are described as functionally dissimilar to a shock-absorber manufacturer, while a plastic auto-components manufacturer was rejected for failing the related-party transactions filter. The text states that such dissimilar or filter-failing comparables are to be excluded. en-us Wed, 27 May 2026 00:00:00 +0530 Tue, 16 Jun 2026 08:32:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793431 In transfer pricing comparability for auto-component manufacturing, the Safe Harbour definitions of core and non-core auto components may be used as a guiding reference in FAR analysis even where the assessee has not opted into the Safe Harbour regime. The core versus non-core distinction is treated as relevant to product character, pricing dynamics, and functional differences under TNMM. On comparables, helmet manufacturers, a railway-locomotive products manufacturer, and a two-wheeler/commercial vehicle manufacturer are described as functionally dissimilar to a shock-absorber manufacturer, while a plastic auto-components manufacturer was rejected for failing the related-party transactions filter. The text states that such dissimilar or filter-failing comparables are to be excluded. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793431