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2023 (3) TMI 388 - AT - Income TaxTP Adjustment - Comparable selection - application of turnover filter - HELD THAT:- Four companies listed whose turnover in the current year is more than Rs.200 Crores should be excluded from the list of comparable companies. Functional dissimilarity - Set aside the question of comparability of CES Ltd., to the TPO/AO to examine as to whether the functional profile of the assessee and the assessees in the decisions cited by the learned AR remains the same in Assessment Year 2017-18 as it was in Assessment Year 2016-17. We set aside the question of comparability of Manipal Digital Systems Pvt.Ltd., to the TPO/AO to examine as to whether the functional profile of the assessee and the assessees in the decisions cited by the learned AR remains the same in Assessment Year 2017-18 as it was in Assessment Year 2016-17.
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