Non profit company not a comparable for Transfer Pricing. ITAT directed AO to exclude it from the list of comparables…
Capacity Utilization Adjustment in transfer pricing allowed for early years of operation where comparables had on average higher utilization ABCAUS…
Exclusion inclusion of comparables to determine Arm's Length Price (ALP) not necessarily give rise to purely legal or substantial questions…
High Court upheld inclusion and exclusion of comparables by TPO based on filters of losses, declining sales, segment reporting employee…
Comparable company following calendar year for maintaining accounts can not be used in contrast to assessee following financial year ending…
In a recent judgment, ITAT Delhi has held that Knowledge Process Outsourcing Services (KPO Services) provider could not be be…