Transfer Pricing Adjustments: Rule 10B(2) Requires Functional Similarity, Not Just Judicial Precedents, for Comparable Selection.

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....TP Adjustment - comparable selection - before relying upon any judicial precedent for exclusion or inclusion one has to cross the threshold of rule 10 B (2) of IT Rules, to ensure that the conditions specified therein are similar as decided by the honourable courts - argument that comparables should be excluded based on judicial precedents without looking at the functional identity of assessee vis a vis comparable is not acceptable....