https://www.taxtmi.com/caselaws?id=794059 A comparable may be excluded from transfer pricing benchmarking where its financial statements show proven irregularities and abnormal margin volatility, because such distortions undermine reliability of operating margins. On support services, a subsequent APA can have persuasive value for a non-APA year where the transaction profile and FAR remain unchanged and documentary evidence supports the service arrangement and benchmarked margin. The commentary also notes that consistent co-ordinate bench views support exclusion of a tainted comparable and recognition of APA-aligned margins in similar later-year transactions. The result described is rejection of the Revenue's challenge and maintenance of the transfer pricing relief. en-us Thu, 30 Apr 2026 00:00:00 +0530 Mon, 29 Jun 2026 09:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794059 A comparable may be excluded from transfer pricing benchmarking where its financial statements show proven irregularities and abnormal margin volatility, because such distortions undermine reliability of operating margins. On support services, a subsequent APA can have persuasive value for a non-APA year where the transaction profile and FAR remain unchanged and documentary evidence supports the service arrangement and benchmarked margin. The commentary also notes that consistent co-ordinate bench views support exclusion of a tainted comparable and recognition of APA-aligned margins in similar later-year transactions. The result described is rejection of the Revenue's challenge and maintenance of the transfer pricing relief. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794059