Wednesday, 23 October 2013

TP adjustments set aside as ALP travelled to safe zone with exclusion of functionally dissimilar com

IT/ILT: Where in course of transfer pricing proceedings, TPO made certain addition to assessee's ALP, in view of fact that some of comparables selected by TPO were improper on account of functional difference and happening of extraordinary events resulting in abnormal profits and, if those comparables were excluded, assessee's profit margin was higher than remaining comparables, impugned addition made by authorities below was to be set aside


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