https://www.taxtmi.com/caselaws?id=800118 Transfer-pricing comparable selection is a factual, data-driven exercise governed by Rule 10B and ordinarily permits interference only where findings are contrary to law or perverse. Functional dissimilarity justified excluding two companies from the arm's length price analysis. As no material established factual error or perversity in the comparability findings, the exclusion was sustained and the substantial questions of law were resolved for the assessee. en-us Thu, 17 Sep 2026 00:00:00 +0530 Thu, 01 Oct 2026 07:40:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800118 Transfer-pricing comparable selection is a factual, data-driven exercise governed by Rule 10B and ordinarily permits interference only where findings are contrary to law or perverse. Functional dissimilarity justified excluding two companies from the arm's length price analysis. As no material established factual error or perversity in the comparability findings, the exclusion was sustained and the substantial questions of law were resolved for the assessee. Case-Laws Income Tax Thu, 17 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800118