https://www.taxtmi.com/caselaws?id=800396 Section 92C(3)(c) permits fresh determination of the arm's length price only where the data used in a transfer-pricing study is unreliable or incorrect. Rejecting a database search without identifying defects in the databases, keywords, filters, methodology or functional analysis does not establish unreliability. Applying additional filters alone is insufficient to displace the taxpayer's search. The additional filters should instead be incorporated into the existing search, followed by verification of whether exclusions are justified by comparability of functions, assets and risks. On this basis, rejection of the transfer-pricing study is not valid. en-us Mon, 21 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800396 Section 92C(3)(c) permits fresh determination of the arm's length price only where the data used in a transfer-pricing study is unreliable or incorrect. Rejecting a database search without identifying defects in the databases, keywords, filters, methodology or functional analysis does not establish unreliability. Applying additional filters alone is insufficient to displace the taxpayer's search. The additional filters should instead be incorporated into the existing search, followed by verification of whether exclusions are justified by comparability of functions, assets and risks. On this basis, rejection of the transfer-pricing study is not valid. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800396