https://www.taxtmi.com/highlights?id=105457 Arm's length price determination under TNMM permits exclusion of comparables initially selected by either party where Rule 10B comparability requirements are not met; initial selection creates no estoppel. Related-party transaction filters may exclude companies whose profitability is materially influenced by controlled dealings, including transactions affecting operating costs rather than only revenue. Contact-centre service benchmarking also requires exclusion where financial results are abnormal, outsourcing models materially differ, segmental profitability is unreliable, or diversified, branded, or higher-end service operations lack reliable segmental data. Material profitability differences must be reliably adjusted; otherwise, the company cannot remain an uncontrolled comparable. en-us Tue, 27 Oct 2026 14:35:24 +0530 Tue, 27 Oct 2026 14:35:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105457 Arm's length price determination under TNMM permits exclusion of comparables initially selected by either party where Rule 10B comparability requirements are not met; initial selection creates no estoppel. Related-party transaction filters may exclude companies whose profitability is materially influenced by controlled dealings, including transactions affecting operating costs rather than only revenue. Contact-centre service benchmarking also requires exclusion where financial results are abnormal, outsourcing models materially differ, segmental profitability is unreliable, or diversified, branded, or higher-end service operations lack reliable segmental data. Material profitability differences must be reliably adjusted; otherwise, the company cannot remain an uncontrolled comparable. Highlights Income Tax Tue, 27 Oct 2026 14:35:24 +0530 https://www.taxtmi.com/highlights?id=105457