Wednesday 23 April 2014

ITAT set aside TP adjustments functionally inappropriate comparables were selected by TPO

IT/ILT : Wherein transfer pricing proceedings, TPO made certain adjustment to assessee's ALP in respect of import of traded goods, in view of fact that some of comparables selected by TPO were inappropriate on account of functional difference and, moreover, after excluding certain unrelated expenses such as depreciation on let out building, write off of fixed assets etc., assessee's operating margin was higher than that of remaining comparable adopted by TPO, impugned adjustment made to assessee


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