https://www.taxtmi.com/caselaws?id=470620 An omitted comparable may be considered in transfer-pricing proceedings where its actual comparability is established, as no estoppel prevents an assessee from seeking inclusion to determine the correct arm's length price. The Contract Manufacturing segment's arm's length price was to be recomputed under the Transactional Net Margin Method using single-year data after a merits-based Functions, Assets and Risks review of four additional companies, while retaining the original comparables. Depreciation and additional depreciation on interest capitalised under the DRP's direction were to be granted, and the claim for depreciation on earlier-year capitalised disallowances was to be examined and implemented after hearing the assessee. en-us Tue, 03 Dec 2019 00:00:00 +0530 Sat, 01 Aug 2026 13:20:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470620 An omitted comparable may be considered in transfer-pricing proceedings where its actual comparability is established, as no estoppel prevents an assessee from seeking inclusion to determine the correct arm's length price. The Contract Manufacturing segment's arm's length price was to be recomputed under the Transactional Net Margin Method using single-year data after a merits-based Functions, Assets and Risks review of four additional companies, while retaining the original comparables. Depreciation and additional depreciation on interest capitalised under the DRP's direction were to be granted, and the claim for depreciation on earlier-year capitalised disallowances was to be examined and implemented after hearing the assessee. Case-Laws Income Tax Tue, 03 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470620