https://www.taxtmi.com/caselaws?id=797014 Transfer-pricing comparables may be excluded where the proposed company's functions, products or end-use materially differ from those of the tested party, particularly where reliable segmental data is unavailable. Bilcare Ltd. was unsuitable because its diverse pharmaceutical packaging and service activities differed from paper-based aseptic food-and-beverage packaging, and current-year segmental data was absent. Karur KCP Packaging Ltd. was also unsuitable because its kraft paper and polypropylene bags served the cement industry and differed in products and end-use. These fact-specific exclusions do not raise a substantial question of law absent perversity. en-us Wed, 05 Aug 2026 00:00:00 +0530 Fri, 14 Aug 2026 07:18:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797014 Transfer-pricing comparables may be excluded where the proposed company's functions, products or end-use materially differ from those of the tested party, particularly where reliable segmental data is unavailable. Bilcare Ltd. was unsuitable because its diverse pharmaceutical packaging and service activities differed from paper-based aseptic food-and-beverage packaging, and current-year segmental data was absent. Karur KCP Packaging Ltd. was also unsuitable because its kraft paper and polypropylene bags served the cement industry and differed in products and end-use. These fact-specific exclusions do not raise a substantial question of law absent perversity. Case-Laws Income Tax Wed, 05 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797014