https://www.taxtmi.com/caselaws?id=801756 Functional comparability under the Transactional Net Margin Method requires a contemporaneous analysis of functions performed, assets deployed and risks assumed; broad functional similarity alone does not establish comparability. The disputed freight-forwarding comparables require fresh consideration through that analysis, with an opportunity of hearing. A working capital adjustment under Rule 10B(3) may be examined where it improves comparability between the tested party and selected comparables, even if the claim was not raised before the Dispute Resolution Panel. That adjustment requires a merits determination after hearing. en-us Fri, 03 Jul 2026 00:00:00 +0530 Tue, 27 Oct 2026 08:33:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801756 Functional comparability under the Transactional Net Margin Method requires a contemporaneous analysis of functions performed, assets deployed and risks assumed; broad functional similarity alone does not establish comparability. The disputed freight-forwarding comparables require fresh consideration through that analysis, with an opportunity of hearing. A working capital adjustment under Rule 10B(3) may be examined where it improves comparability between the tested party and selected comparables, even if the claim was not raised before the Dispute Resolution Panel. That adjustment requires a merits determination after hearing. Case-Laws Income Tax Fri, 03 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801756