https://www.taxtmi.com/caselaws?id=470102 Transfer-pricing comparability under Rules 10B(2) and 10B(3) requires consistent data and consideration of prevailing market conditions and material profit-affecting differences. Where exceptional recessionary conditions affect the tested party's relevant year, comparable companies' multiple-year weighted margins should not be benchmarked against the tested party's single-year margin unless earlier-year transactions remain comparable. The notes state that arm's length pricing should use comparable and tested-party results for the same financial year. They also address R&D expenditure: actual expenditure corresponding to a denied weighted deduction may be considered under Section 35(1)(iv), subject to verification of the expenditure and statutory eligibility. en-us Tue, 03 Jun 2025 00:00:00 +0530 Wed, 15 Jul 2026 18:59:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470102 Transfer-pricing comparability under Rules 10B(2) and 10B(3) requires consistent data and consideration of prevailing market conditions and material profit-affecting differences. Where exceptional recessionary conditions affect the tested party's relevant year, comparable companies' multiple-year weighted margins should not be benchmarked against the tested party's single-year margin unless earlier-year transactions remain comparable. The notes state that arm's length pricing should use comparable and tested-party results for the same financial year. They also address R&D expenditure: actual expenditure corresponding to a denied weighted deduction may be considered under Section 35(1)(iv), subject to verification of the expenditure and statutory eligibility. Case-Laws Income Tax Tue, 03 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470102