https://www.taxtmi.com/caselaws?id=794457 In transfer pricing comparability, size and turnover are relevant filters and comparability must be tested afresh each year; ADS Diagnostics Ltd. was properly excluded for failing the turnover filter, even though it had been accepted earlier. Under TNMM, functional similarity must also be broadly established, and Riviera Glass Ltd. was correctly excluded because its laboratory glassware and related business was not broadly comparable to medical devices. Subvention receipts linked to an associated enterprise pricing arrangement were treated as operating-cost offsets, not operating revenue, and the operating margin was directed to be computed at 5.04%. en-us Thu, 11 Jun 2026 00:00:00 +0530 Mon, 06 Jul 2026 08:26:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794457 In transfer pricing comparability, size and turnover are relevant filters and comparability must be tested afresh each year; ADS Diagnostics Ltd. was properly excluded for failing the turnover filter, even though it had been accepted earlier. Under TNMM, functional similarity must also be broadly established, and Riviera Glass Ltd. was correctly excluded because its laboratory glassware and related business was not broadly comparable to medical devices. Subvention receipts linked to an associated enterprise pricing arrangement were treated as operating-cost offsets, not operating revenue, and the operating margin was directed to be computed at 5.04%. Case-Laws Income Tax Thu, 11 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794457