2010 (11) TMI 852 - ITAT DELHI

TPA - Comparable selection - HELD THAT:- On considering the facts of the case, We find that there is no dispute on the issue that cost plus method is the most appropriate method for valuing controlled-international transactions in this case The assessee had selected 23 comparables and adjustment was made towards working capital. On this basis the mean of the comparables was worked out 10% against the margin of 17% shown by the assessee. the results of the assessee are in line with the mean margin of comparable cases even if no adjustment is made on account of capital etc. Therefore, it is held that no adjustment was required to be made to the results declared by the assessee company.

In the result, the appeal is allowed.