https://www.taxtmi.com/highlights?id=105043 PBDIT was treated as the appropriate profit level indicator for manufacturing transactions where materially higher fixed assets and depreciation distorted comparability under the operating-profit-to-operating-cost indicator and no reliable depreciation adjustment to comparables was feasible. The taxpayer's and comparables' margins were therefore to be recomputed on a PBDIT basis. A working-capital adjustment was required in benchmarking the international transactions. Set-off of brought-forward business losses and unabsorbed depreciation was mandatory under the Act, subject to verification of the losses available, because the final assessment did not consider or give reasons for denying the claim. en-us Fri, 16 Oct 2026 05:20:55 +0530 Fri, 16 Oct 2026 05:20:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105043 PBDIT was treated as the appropriate profit level indicator for manufacturing transactions where materially higher fixed assets and depreciation distorted comparability under the operating-profit-to-operating-cost indicator and no reliable depreciation adjustment to comparables was feasible. The taxpayer's and comparables' margins were therefore to be recomputed on a PBDIT basis. A working-capital adjustment was required in benchmarking the international transactions. Set-off of brought-forward business losses and unabsorbed depreciation was mandatory under the Act, subject to verification of the losses available, because the final assessment did not consider or give reasons for denying the claim. Highlights Income Tax Fri, 16 Oct 2026 05:20:55 +0530 https://www.taxtmi.com/highlights?id=105043