https://www.taxtmi.com/caselaws?id=469394 In transfer pricing, additional comparables were not to be rejected merely because they were absent from the original study; the assessee had to be allowed to place bona fide material and explain their relevance, so the matter was sent back for fresh consideration. Jeevan Softech Ltd. and BNR Udyog Ltd. were found functionally dissimilar to design engineering services, and BNR Udyog Ltd. also failed the related party transactions filter, so both were excluded. Operating margin computation and working capital adjustment were also remanded for recomputation after the comparable set changed. Section 10A deduction was to be computed undertaking-wise before set-off of losses of the non-eligible unit, and the claim was allowed. en-us Wed, 23 May 2018 00:00:00 +0530 Tue, 16 Jun 2026 14:10:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469394 In transfer pricing, additional comparables were not to be rejected merely because they were absent from the original study; the assessee had to be allowed to place bona fide material and explain their relevance, so the matter was sent back for fresh consideration. Jeevan Softech Ltd. and BNR Udyog Ltd. were found functionally dissimilar to design engineering services, and BNR Udyog Ltd. also failed the related party transactions filter, so both were excluded. Operating margin computation and working capital adjustment were also remanded for recomputation after the comparable set changed. Section 10A deduction was to be computed undertaking-wise before set-off of losses of the non-eligible unit, and the claim was allowed. Case-Laws Income Tax Wed, 23 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469394