https://www.taxtmi.com/caselaws?id=469697 Transfer pricing comparability requires functional similarity, so a diversified company with multiple business segments cannot be adopted on a consolidated basis where only the automobile segment matches the assessee; the matter was remitted to select the relevant segment or another suitable comparable. The revised DRP/TPO adjustment also required verification in the final assessment order and was sent back to the AO. Valuation of old machinery purchased from an AE could not be fixed at nil without adequate material, so the issue was remitted for TPO/DVO valuation. Corporate club membership fee and brought-forward loss or depreciation were likewise sent back for fresh examination and verification. en-us Thu, 07 Apr 2016 00:00:00 +0530 Mon, 29 Jun 2026 20:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469697 Transfer pricing comparability requires functional similarity, so a diversified company with multiple business segments cannot be adopted on a consolidated basis where only the automobile segment matches the assessee; the matter was remitted to select the relevant segment or another suitable comparable. The revised DRP/TPO adjustment also required verification in the final assessment order and was sent back to the AO. Valuation of old machinery purchased from an AE could not be fixed at nil without adequate material, so the issue was remitted for TPO/DVO valuation. Corporate club membership fee and brought-forward loss or depreciation were likewise sent back for fresh examination and verification. Case-Laws Income Tax Thu, 07 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469697