https://www.taxtmi.com/caselaws?id=469613 Persistent-loss exclusion requires verification of the relevant past-year results before a company is treated as an unsuitable comparable. TD Power Systems Ltd. was therefore remanded to the AO/TPO for fresh examination after the Tribunal noted past profits and the need for factual verification. Inox Wind Ltd. was excluded from the manufacturing comparables set because its integrated wind energy business, including manufacturing, EPC, operations and maintenance, and power sales, was materially different and its segmental data did not reliably isolate manufacturing income. Suzlon Energy Ltd. was also excluded because merger/demerger events and mixed revenue streams without usable segmental separation made functional comparison unreliable. The appeal was partly allowed in favour of the assessee. en-us Wed, 31 May 2023 00:00:00 +0530 Wed, 24 Jun 2026 15:33:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469613 Persistent-loss exclusion requires verification of the relevant past-year results before a company is treated as an unsuitable comparable. TD Power Systems Ltd. was therefore remanded to the AO/TPO for fresh examination after the Tribunal noted past profits and the need for factual verification. Inox Wind Ltd. was excluded from the manufacturing comparables set because its integrated wind energy business, including manufacturing, EPC, operations and maintenance, and power sales, was materially different and its segmental data did not reliably isolate manufacturing income. Suzlon Energy Ltd. was also excluded because merger/demerger events and mixed revenue streams without usable segmental separation made functional comparison unreliable. The appeal was partly allowed in favour of the assessee. Case-Laws Income Tax Wed, 31 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469613