https://www.taxtmi.com/caselaws?id=472665 TNMM benchmarking requires a functionally comparable entity not to be excluded solely because it is persistently loss-making; exclusion depends on abnormal conditions evidenced from data up to the relevant year. Cash profit before depreciation may serve as the profit-level indicator where differing depreciation practices are substantiated, and operating-profit-to-operating-revenue workings must be disclosed to permit verification. Functional comparability of entities with diversified activities, differing turnover, or fabricated-item revenue requires verification of the business profile, relationship of activities, and availability of segmental information. Turnover filters and inclusion or exclusion must rest on established functional facts rather than assumptions, with fresh determination where the record is inadequate. en-us Fri, 17 May 2019 00:00:00 +0530 Wed, 21 Oct 2026 18:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472665 TNMM benchmarking requires a functionally comparable entity not to be excluded solely because it is persistently loss-making; exclusion depends on abnormal conditions evidenced from data up to the relevant year. Cash profit before depreciation may serve as the profit-level indicator where differing depreciation practices are substantiated, and operating-profit-to-operating-revenue workings must be disclosed to permit verification. Functional comparability of entities with diversified activities, differing turnover, or fabricated-item revenue requires verification of the business profile, relationship of activities, and availability of segmental information. Turnover filters and inclusion or exclusion must rest on established functional facts rather than assumptions, with fresh determination where the record is inadequate. Case-Laws Income Tax Fri, 17 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472665