Karnataka HC says Transfer Pricing Requires Case Specific Comparability Analysis

In a batch of transfer pricing appeals arising from the Supreme Court's remand in SAP Labs India, the Karnataka High Court laid down detailed principles on comparables, turnover and RPT filters, foreign exchange gains/losses, subsequent data and working-capital adjustments. 

The Court emphasised that transfer pricing is a fact and data-driven exercise and that the TPO cannot replace the taxpayer's comparables with a standard departmental set without satisfying the statutory comparability requirements.