https://www.taxtmi.com/caselaws?id=472197 Transfer-pricing comparability requires valid economic criteria, including uniform application of a ten-times turnover filter; prior inclusion in a taxpayer's study does not prevent a later comparability challenge. Functional comparability requires verification of functions, assets and risks, including relevant filters for disputed companies. Foreign-currency receivables should be benchmarked to the relevant foreign-currency market rate, with LIBOR plus 200 basis points applied instead of domestic rupee rates. Provisions for bad and doubtful debts are not operating costs because they do not represent actual expenditure. Negative working-capital adjustments require examination of working-capital risk and an adequate opportunity to be heard. en-us Wed, 16 Apr 2025 00:00:00 +0530 Fri, 02 Oct 2026 09:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472197 Transfer-pricing comparability requires valid economic criteria, including uniform application of a ten-times turnover filter; prior inclusion in a taxpayer's study does not prevent a later comparability challenge. Functional comparability requires verification of functions, assets and risks, including relevant filters for disputed companies. Foreign-currency receivables should be benchmarked to the relevant foreign-currency market rate, with LIBOR plus 200 basis points applied instead of domestic rupee rates. Provisions for bad and doubtful debts are not operating costs because they do not represent actual expenditure. Negative working-capital adjustments require examination of working-capital risk and an adequate opportunity to be heard. Case-Laws Income Tax Wed, 16 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472197