TNMM comparable selection in medical-equipment trading: functional similarity, RPT checks, and margin verification guided ITAT's approach.

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....Under TNMM, comparables engaged in trading of medical equipment were retained where product identity was not required and the assessee had not challenged the TPO's search keywords. MDD Medical Systems Pvt. Ltd. and RMD Mediaids Ltd. were not excluded on the basis of alleged support-services activity, research and development, or product dissimilarity because their financials indicated product sales and similar trading functions. QMS Medical Allied Services Pvt. Ltd. was not treated as an extraordinary-event comparable merely because of fresh capital infusion, although the Assessing Officer was directed to verify the margin computation. Hoya Medical India Pvt. Ltd. and Hicks Thermometer (India) Pvt. Ltd. were remitted for verification of RPT compliance, filters, and functional profile, with exclusion or inclusion to follow the verified results.....