https://www.taxtmi.com/caselaws?id=799298 Condonation of delay may be supported by COVID-19 disruption and the overseas location of key decision-makers where the explanation shows no mala fides. Transfer-pricing comparability requires reliable relevant-year financial and functional information, material functional similarity, and satisfaction of applied quantitative filters. Companies without verifiable public data, performing highly technical infrastructure-project services involving brand intangibles, carrying out government-driven diversified activities, or failing the employee-cost filter are excluded from the comparable set. The arm's length price determination excludes the four challenged comparables. en-us Thu, 10 Sep 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799298 Condonation of delay may be supported by COVID-19 disruption and the overseas location of key decision-makers where the explanation shows no mala fides. Transfer-pricing comparability requires reliable relevant-year financial and functional information, material functional similarity, and satisfaction of applied quantitative filters. Companies without verifiable public data, performing highly technical infrastructure-project services involving brand intangibles, carrying out government-driven diversified activities, or failing the employee-cost filter are excluded from the comparable set. The arm's length price determination excludes the four challenged comparables. Case-Laws Income Tax Thu, 10 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799298