https://www.taxtmi.com/caselaws?id=470102 Transfer-pricing comparability must account for prevailing market conditions and material profit-affecting differences under Rules 10B(2) and 10B(3). Where exceptional recessionary conditions affected the automobile and auto-component sector in FY 2019-20, comparable companies' results for that same year should be compared with the tested party's FY 2019-20 results; three-year weighted comparable margins should not be benchmarked against a single-year tested-party margin when earlier-year conditions are not comparable. Actual R&D expenditure corresponding to a denied weighted deduction may be examined for deduction under Section 35(1)(iv), subject to verification of 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 must account for prevailing market conditions and material profit-affecting differences under Rules 10B(2) and 10B(3). Where exceptional recessionary conditions affected the automobile and auto-component sector in FY 2019-20, comparable companies' results for that same year should be compared with the tested party's FY 2019-20 results; three-year weighted comparable margins should not be benchmarked against a single-year tested-party margin when earlier-year conditions are not comparable. Actual R&D expenditure corresponding to a denied weighted deduction may be examined for deduction under Section 35(1)(iv), subject to verification of eligibility. Case-Laws Income Tax Tue, 03 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470102