https://www.taxtmi.com/caselaws?id=470636 A fresh assessment made pursuant to a revision order lacks legal foundation once that revision order is set aside, leaving the original regular assessment operative. For transfer-pricing comparability, turnover may be used as a filter where enterprise size materially affects comparability, but the appropriate band depends on the tested party's turnover and available functionally comparable companies; the notes describe a one-tenth-to-ten-times range. Functionally dissimilar packaging companies should be excluded, while a company with reliable segmental data for the relevant packaging/plastics segment may be included. Working capital adjustment is required for reliable operating-margin comparison, subject to verification and recomputation of the relevant data. en-us Fri, 24 May 2019 00:00:00 +0530 Mon, 03 Aug 2026 10:59:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470636 A fresh assessment made pursuant to a revision order lacks legal foundation once that revision order is set aside, leaving the original regular assessment operative. For transfer-pricing comparability, turnover may be used as a filter where enterprise size materially affects comparability, but the appropriate band depends on the tested party's turnover and available functionally comparable companies; the notes describe a one-tenth-to-ten-times range. Functionally dissimilar packaging companies should be excluded, while a company with reliable segmental data for the relevant packaging/plastics segment may be included. Working capital adjustment is required for reliable operating-margin comparison, subject to verification and recomputation of the relevant data. Case-Laws Income Tax Fri, 24 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470636