Monday, 6 July 2015

Companies having related party transactions in excess of 15% can't be selected as comparable for TP

IT/ILT : Where TPO made addition to assessee's ALP in respect of rendering research and development services to its AE, in view of fact that two comparables selected by TPO were functionally not comparable as R&D service providers whereas another comparable was found inappropriate as it had related party transactions in excess of 15 per cent, impugned addition was to be set aside

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