https://www.taxtmi.com/caselaws?id=471803 Transfer-pricing analysis must account for material economic differences affecting comparability and margins, including capacity utilisation, working capital, customs duty and cash PLI. Functional comparability may be reassessed even for companies initially selected by the taxpayer, subject to factual verification. Comparable-company margin corrections require verification and appropriate incorporation. A corroborative approach using the associated enterprise as the tested party requires a comprehensive study under applicable law. Alternative arm's length price computations and related adjustment claims require reasoned consideration through a speaking order after an opportunity of hearing; unresolved matters require fresh determination. en-us Wed, 07 Feb 2018 00:00:00 +0530 Fri, 18 Sep 2026 18:14:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471803 Transfer-pricing analysis must account for material economic differences affecting comparability and margins, including capacity utilisation, working capital, customs duty and cash PLI. Functional comparability may be reassessed even for companies initially selected by the taxpayer, subject to factual verification. Comparable-company margin corrections require verification and appropriate incorporation. A corroborative approach using the associated enterprise as the tested party requires a comprehensive study under applicable law. Alternative arm's length price computations and related adjustment claims require reasoned consideration through a speaking order after an opportunity of hearing; unresolved matters require fresh determination. Case-Laws Income Tax Wed, 07 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471803