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2018 (10) TMI 677 - AT - Income TaxTransfer pricing - selection of comparable - none of the companies selected by the TPO are engaged in the activity of lease and sub-lease of the vessels - Held that:- the issue needs verification by the Ld.TPO/AO to select the correct comparables functionally, asset wise to arrive at the PLI to bench mark and arrive at the ALP. Therefore, in the interest of justice, we restore the matter back to the file of the Ld.TPO/AO to determine ALP after making proper transfer pricing study. - Matter remanded back.
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