https://www.taxtmi.com/caselaws?id=800976 Comparable selection for determining arm's length price under Rule 10B requires functional comparability and is a factual, data-driven exercise. Accurate Data Converters Limited was properly excluded because it outsourced a major part of its work and was not functionally comparable to the assessee. No material established perversity, reliance on irrelevant material, or exclusion of relevant material in the factual basis supporting exclusion. The arm's length price analysis therefore excluded that company as a comparable. en-us Thu, 24 Sep 2026 00:00:00 +0530 Wed, 14 Oct 2026 06:17:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800976 Comparable selection for determining arm's length price under Rule 10B requires functional comparability and is a factual, data-driven exercise. Accurate Data Converters Limited was properly excluded because it outsourced a major part of its work and was not functionally comparable to the assessee. No material established perversity, reliance on irrelevant material, or exclusion of relevant material in the factual basis supporting exclusion. The arm's length price analysis therefore excluded that company as a comparable. Case-Laws Income Tax Thu, 24 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800976