https://www.taxtmi.com/caselaws?id=801088 Transfer-pricing comparability under Rule 10B requires assessment of market conditions, assets employed and risks assumed. As the Rules prescribe no statutory upper or lower turnover threshold, an upper turnover filter of Rs. 200 crore can be applied as a rational factual benchmark for determining the arm's length price. Interference with that comparability determination requires a specific showing of perversity. Application of the Rs. 200 crore upper turnover filter was treated as valid in the assessee's transfer-pricing analysis. en-us Mon, 28 Sep 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801088 Transfer-pricing comparability under Rule 10B requires assessment of market conditions, assets employed and risks assumed. As the Rules prescribe no statutory upper or lower turnover threshold, an upper turnover filter of Rs. 200 crore can be applied as a rational factual benchmark for determining the arm's length price. Interference with that comparability determination requires a specific showing of perversity. Application of the Rs. 200 crore upper turnover filter was treated as valid in the assessee's transfer-pricing analysis. Case-Laws Income Tax Mon, 28 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801088