Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed...

Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed u/r 10B(4) for using multiple year data. Assessee required to perform Functional Asset and Risk (FAR) analysis for each year as factors of comparability may differ. Previous years' data cannot be extrapolated without establishing identical comparability factors. TP study report relying on previous two years' data without current year data rightly rejected. Comparables selection in manufacturing segment - Rejection of certain comparables upheld due to differences in product, raw material, related party transactions exceeding 25%, and impact of intangibles on margins. Remitted to TPO to examine export filter objection for one comparable. TP a..... .....

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