https://www.taxtmi.com/caselaws?id=802664 Transfer-pricing comparability depends on functions, assets, risks and market conditions. Turnover differences may affect those factors, but turnover alone does not require exclusion where other comparability criteria are satisfied. Differences in intangibles, functions or scale, and insufficient service details, may affect comparability. Under the transactional net margin method, working capital differences materially affecting net margins require adjustment to comparable companies' margins. Deduction of service expenditure requires it to be incurred wholly and exclusively for business and supported by evidence of actual service rendition. Invoices, agreements, ledger entries and payment records did not establish service rendition; the assessment also relied on investigation findings, input tax credit reversal, unanswered vendor notices and independent enquiries. en-us Tue, 06 Oct 2026 00:00:00 +0530 Fri, 13 Nov 2026 08:45:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802664 Transfer-pricing comparability depends on functions, assets, risks and market conditions. Turnover differences may affect those factors, but turnover alone does not require exclusion where other comparability criteria are satisfied. Differences in intangibles, functions or scale, and insufficient service details, may affect comparability. Under the transactional net margin method, working capital differences materially affecting net margins require adjustment to comparable companies' margins. Deduction of service expenditure requires it to be incurred wholly and exclusively for business and supported by evidence of actual service rendition. Invoices, agreements, ledger entries and payment records did not establish service rendition; the assessment also relied on investigation findings, input tax credit reversal, unanswered vendor notices and independent enquiries. Case-Laws Income Tax Tue, 06 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802664