Wednesday 12 August 2015

Fluctuating margin of a company over years doesn't justify its exclusion from list of comparables

IT/ILT: Where TPO made addition to assessee's ALP by rejecting comparables chosen by assessee in its TP study, in view of fact that certain comparables chosen by TPO were not found to be comparable on account of functional difference, absence of segmental details, possessing tangibles or IPRs, related party transactions etc. same had to be excluded

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