https://www.taxtmi.com/caselaws?id=798349 Prospective omission of the specified-domestic-transaction provision from assessment year 2017-18 did not invalidate transfer-pricing assessment for assessment year 2013-14, applying strict construction of taxing statutes. Comparable selection required functional similarity: accumulated losses or abnormal profitability alone did not justify exclusion where adjustments were feasible, while plastic-container and moulded-plastic manufacturers were unsuitable comparables. The arm's length price required consequential recomputation. Exempt-income expenditure disallowance required recomputation using only investments yielding dividend income. Preliminary expenditure incurred to explore a manufacturing-related venture that was ultimately abandoned retained its revenue character and was allowable. en-us Wed, 02 Sep 2026 00:00:00 +0530 Sat, 05 Sep 2026 08:44:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798349 Prospective omission of the specified-domestic-transaction provision from assessment year 2017-18 did not invalidate transfer-pricing assessment for assessment year 2013-14, applying strict construction of taxing statutes. Comparable selection required functional similarity: accumulated losses or abnormal profitability alone did not justify exclusion where adjustments were feasible, while plastic-container and moulded-plastic manufacturers were unsuitable comparables. The arm's length price required consequential recomputation. Exempt-income expenditure disallowance required recomputation using only investments yielding dividend income. Preliminary expenditure incurred to explore a manufacturing-related venture that was ultimately abandoned retained its revenue character and was allowable. Case-Laws Income Tax Wed, 02 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798349