https://www.taxtmi.com/caselaws?id=471637 Transfer-pricing comparability requires adjustments for material differences in import content, raw-material consumption, capacity utilisation and scrap sales; separate working-capital adjustment may be unnecessary where those differences are addressed. Safe Harbour Rules introduced prospectively cannot govern prior transfer-pricing documentation, and provision write-backs may be operating items. Companies with product, brand, significant research-and-development or functionally diverse operations may be unsuitable comparables, while different financial years may be reconciled through audited quarterly data. Warranty provisions require a present sales-related obligation, probable outflow and reliable estimation. Actual bad-debt write-offs and business-linked trade-advance write-offs may qualify for deduction, and depreciation must follow binding directions. en-us Thu, 08 Oct 2020 00:00:00 +0530 Fri, 11 Sep 2026 16:54:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471637 Transfer-pricing comparability requires adjustments for material differences in import content, raw-material consumption, capacity utilisation and scrap sales; separate working-capital adjustment may be unnecessary where those differences are addressed. Safe Harbour Rules introduced prospectively cannot govern prior transfer-pricing documentation, and provision write-backs may be operating items. Companies with product, brand, significant research-and-development or functionally diverse operations may be unsuitable comparables, while different financial years may be reconciled through audited quarterly data. Warranty provisions require a present sales-related obligation, probable outflow and reliable estimation. Actual bad-debt write-offs and business-linked trade-advance write-offs may qualify for deduction, and depreciation must follow binding directions. Case-Laws Income Tax Thu, 08 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471637