https://www.taxtmi.com/caselaws?id=798685 Transfer-pricing comparables must be selected or rejected under the statutory conditions and Rule 10B factors; fact-based determinations are generally insulated from section 260A review absent legal breach or perversity. Turnover and related-party transaction filters are sustainable when rationally tied to reliable comparability, while working-capital adjustments remain data-dependent. Foreign-exchange gains or losses qualify as operating items only on proof of direct nexus with the international transaction, requiring factual verification where unresolved. The 5% variation under section 92C(2) is a tolerance range, not a deduction, and section 92C(2A) applies retrospectively from assessment year 2002-03; affected matters require fresh determination. Cross-objections are not maintainable under section 260A. en-us Fri, 28 Aug 2026 00:00:00 +0530 Thu, 10 Sep 2026 08:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798685 Transfer-pricing comparables must be selected or rejected under the statutory conditions and Rule 10B factors; fact-based determinations are generally insulated from section 260A review absent legal breach or perversity. Turnover and related-party transaction filters are sustainable when rationally tied to reliable comparability, while working-capital adjustments remain data-dependent. Foreign-exchange gains or losses qualify as operating items only on proof of direct nexus with the international transaction, requiring factual verification where unresolved. The 5% variation under section 92C(2) is a tolerance range, not a deduction, and section 92C(2A) applies retrospectively from assessment year 2002-03; affected matters require fresh determination. Cross-objections are not maintainable under section 260A. Case-Laws Income Tax Fri, 28 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798685