https://www.taxtmi.com/caselaws?id=799036 Advance pricing agreement coverage for earlier years does not bind benchmarking for an uncovered year, but remains persuasive where the transaction, methodology and functional, asset and risk profile continue; departure requires material differences. Comparable companies accepted in the preceding year should not be removed solely under a turnover filter absent a finding that turnover materially affects operating margins, subject to other comparability requirements. A comparable exceeding the adopted related-party transaction threshold must be excluded because segmenting related-party income and expenditure does not eliminate the influence of controlled transactions on overall profitability. Where revised comparables place the tested party's operating margin within the arm's-length percentile range, no transfer-pricing adjustment is warranted. en-us Fri, 28 Aug 2026 00:00:00 +0530 Wed, 16 Sep 2026 08:38:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799036 Advance pricing agreement coverage for earlier years does not bind benchmarking for an uncovered year, but remains persuasive where the transaction, methodology and functional, asset and risk profile continue; departure requires material differences. Comparable companies accepted in the preceding year should not be removed solely under a turnover filter absent a finding that turnover materially affects operating margins, subject to other comparability requirements. A comparable exceeding the adopted related-party transaction threshold must be excluded because segmenting related-party income and expenditure does not eliminate the influence of controlled transactions on overall profitability. Where revised comparables place the tested party's operating margin within the arm's-length percentile range, no transfer-pricing adjustment is warranted. Case-Laws Income Tax Fri, 28 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799036