Monday, 3 June 2013

Similarity should exist among functions and related party transactions for selection of comparables

IT/ILT: Where in course of transfer pricing proceedings, certain adjustment was made to ALP determined by assessee, in view of fact that some of comparables selected by TPO were not appropriate on account of functional difference, related party transactions, turnover filter, etc., impugned adjustment was to be set aside and matter was to be remanded back for disposal afresh


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