https://www.taxtmi.com/caselaws?id=469852 Section 80-IA(10) adjustment could not be sustained without objective material showing a close connection, an arranged course of business and profits above ordinary levels; the record did not establish those foundational facts, so the adjustment failed. On comparables, Neysa Jewellery Ltd. was excluded because abnormal financial stress and audit qualifications made it an unreliable comparator, Goldiam Jewellery Ltd. was included because no cogent basis for exclusion was shown, and Inter Gold (India) Pvt. Ltd. was excluded because related party transactions remained a valid comparability filter. Any transfer pricing impact had to be reflected by recomputing the section 10AA deduction, not as a standalone addition to total income. en-us Fri, 08 May 2026 00:00:00 +0530 Mon, 06 Jul 2026 20:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469852 Section 80-IA(10) adjustment could not be sustained without objective material showing a close connection, an arranged course of business and profits above ordinary levels; the record did not establish those foundational facts, so the adjustment failed. On comparables, Neysa Jewellery Ltd. was excluded because abnormal financial stress and audit qualifications made it an unreliable comparator, Goldiam Jewellery Ltd. was included because no cogent basis for exclusion was shown, and Inter Gold (India) Pvt. Ltd. was excluded because related party transactions remained a valid comparability filter. Any transfer pricing impact had to be reflected by recomputing the section 10AA deduction, not as a standalone addition to total income. Case-Laws Income Tax Fri, 08 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469852