https://www.taxtmi.com/caselaws?id=794299 Under TNMM benchmarking, foreign exchange losses linked to external commercial borrowings and capital expenditure are non-operating and should be excluded from the operating margin; the same treatment was directed here. Comparability must turn on functions, assets, risks and economic context, and ZF Steering Gear (India) Limited was found functionally dissimilar and excluded from the set. The disallowance of expenses was remanded for fresh consideration because additional evidence required examination and the assessee was to be given an opportunity. en-us Fri, 12 Jun 2026 00:00:00 +0530 Fri, 03 Jul 2026 08:49:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794299 Under TNMM benchmarking, foreign exchange losses linked to external commercial borrowings and capital expenditure are non-operating and should be excluded from the operating margin; the same treatment was directed here. Comparability must turn on functions, assets, risks and economic context, and ZF Steering Gear (India) Limited was found functionally dissimilar and excluded from the set. The disallowance of expenses was remanded for fresh consideration because additional evidence required examination and the assessee was to be given an opportunity. Case-Laws Income Tax Fri, 12 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794299