https://www.taxtmi.com/caselaws?id=794888 Transfer pricing benchmarking under the Transactional Net Margin Method concerned whether Universal Petro-Chemicals Ltd. and Iftex Oil and Chemicals Ltd. should be included as comparables for a manufacturing segment involving raw-material purchases. The commentary notes that the entities had previously been accepted by the revenue as functionally comparable for the same segment, while no material distinction was identified for the relevant assessment year. Objections based on alleged cherry-picking, low margins, turnover differences and persistent losses were therefore insufficient to justify their exclusion. Their inclusion brought the assessee's margin within the comparable range and supported determination of the arm's length price using the expanded comparable set. en-us Wed, 18 Feb 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794888 Transfer pricing benchmarking under the Transactional Net Margin Method concerned whether Universal Petro-Chemicals Ltd. and Iftex Oil and Chemicals Ltd. should be included as comparables for a manufacturing segment involving raw-material purchases. The commentary notes that the entities had previously been accepted by the revenue as functionally comparable for the same segment, while no material distinction was identified for the relevant assessment year. Objections based on alleged cherry-picking, low margins, turnover differences and persistent losses were therefore insufficient to justify their exclusion. Their inclusion brought the assessee's margin within the comparable range and supported determination of the arm's length price using the expanded comparable set. Case-Laws Income Tax Wed, 18 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794888