https://www.taxtmi.com/caselaws?id=794789 Functional comparability and reliable segmental data were treated as essential in transfer pricing: diversified businesses, product engineering, proprietary software development, or intangibles-based operations were excluded as comparables, while a different accounting year alone was not enough to reject a company where quarterly data enabled proper margin computation. The DRP could not suo motu exclude companies accepted by both parties without cogent reasons. Chapter X was held mandatory for international transactions notwithstanding section 10A deduction, so arm's length price had to be determined. For section 10A, telecommunication expenses excluded from export turnover also had to be excluded from total turnover. Claims for advance tax, self-assessment tax, TDS and MAT credit were restored for verification and allowance. en-us Tue, 27 Jan 2026 00:00:00 +0530 Sat, 11 Jul 2026 08:46:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794789 Functional comparability and reliable segmental data were treated as essential in transfer pricing: diversified businesses, product engineering, proprietary software development, or intangibles-based operations were excluded as comparables, while a different accounting year alone was not enough to reject a company where quarterly data enabled proper margin computation. The DRP could not suo motu exclude companies accepted by both parties without cogent reasons. Chapter X was held mandatory for international transactions notwithstanding section 10A deduction, so arm's length price had to be determined. For section 10A, telecommunication expenses excluded from export turnover also had to be excluded from total turnover. Claims for advance tax, self-assessment tax, TDS and MAT credit were restored for verification and allowance. Case-Laws Income Tax Tue, 27 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794789