Thursday 15 May 2014

TP addition deleted as functionally dissimilar comparable was chosen by TPO after rejecting suitable

IT/ILT: Where in course of transfer pricing proceedings, TPO made adjustment to assessee's ALP in respect of import of components of automobiles, in view of fact that one of comparables selected by TPO was inappropriate on account of functional difference whereas another comparable rejected had been considered as appropriate comparable by DRP in preceding year, impugned adjustment was to be set aside and matter was to be remanded back for disposal afresh


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