https://www.taxtmi.com/caselaws?id=793481 Transfer pricing comparables cannot be rejected on an unsupported persistent-loss rationale when the record does not show the required loss pattern; Rheal Software Pvt. Ltd. was held includible and Toxsl Technologies Pvt. Ltd. was directed to be included as functionally similar. Advances from customers shown as unearned revenue, supported by invoices and ledgers and taxed in later years, were not unexplained credits under section 68 absent adverse material, so the addition was deleted. Foreign currency fluctuation loss already reflected in the audited accounts and income computation could not be separately added back as understatement of revenue, and that addition was also deleted. Interest and fee were sent back for fresh computation after a fair opportunity. en-us Tue, 26 May 2026 00:00:00 +0530 Wed, 17 Jun 2026 07:46:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793481 Transfer pricing comparables cannot be rejected on an unsupported persistent-loss rationale when the record does not show the required loss pattern; Rheal Software Pvt. Ltd. was held includible and Toxsl Technologies Pvt. Ltd. was directed to be included as functionally similar. Advances from customers shown as unearned revenue, supported by invoices and ledgers and taxed in later years, were not unexplained credits under section 68 absent adverse material, so the addition was deleted. Foreign currency fluctuation loss already reflected in the audited accounts and income computation could not be separately added back as understatement of revenue, and that addition was also deleted. Interest and fee were sent back for fresh computation after a fair opportunity. Case-Laws Income Tax Tue, 26 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793481