Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocation.

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....Transfer pricing comparables were tested on functional and factual suitability: India Tourism Development Corporation Limited was remanded for fresh examination because the loss-maker label was based on a misquoted record and profit had been shown in a relevant year; the healthcare segment of Inhouse Production Ltd. was directed to be included because segmental comparability was established; and Elbit Diagnostics Limited remained excluded because its operational circumstances made it an unsuitable comparable despite the persistent-loss reasoning failing. The Tribunal also directed working capital adjustment in line with the DRP's binding direction, accepted the assessee's no-risk status on a cost-plus, direction-driven model, and rejected objections to use of current-year data and the standard plus/minus 5 percent tolerance benefit.....