https://www.taxtmi.com/caselaws?id=798759 Rule 10B functional comparability requires examination of functions performed, products manufactured and material circumstances; a materially different functional profile supports exclusion of a comparable. Under section 260-A, factual transfer-pricing findings are not re-appreciated unless perverse, unsupported by evidence or contrary to the statutory scheme. Working-capital adjustment requires supporting material and evidence-based computation with reasonable accuracy, warranting examination by the Assessing Officer or Transfer Pricing Officer. A foreign-exchange revenue filter requires a proper, consistent and lawful basis. Transfer-pricing adjustment must be confined to the arm's-length price of relevant international transactions with associated enterprises, including transactions involving raw-material imports. en-us Tue, 25 Aug 2026 00:00:00 +0530 Fri, 11 Sep 2026 08:30:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798759 Rule 10B functional comparability requires examination of functions performed, products manufactured and material circumstances; a materially different functional profile supports exclusion of a comparable. Under section 260-A, factual transfer-pricing findings are not re-appreciated unless perverse, unsupported by evidence or contrary to the statutory scheme. Working-capital adjustment requires supporting material and evidence-based computation with reasonable accuracy, warranting examination by the Assessing Officer or Transfer Pricing Officer. A foreign-exchange revenue filter requires a proper, consistent and lawful basis. Transfer-pricing adjustment must be confined to the arm's-length price of relevant international transactions with associated enterprises, including transactions involving raw-material imports. Case-Laws Income Tax Tue, 25 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798759