2016 (10) TMI 1048

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... sing the margin. Held that:- Quite apart from the fact that tribunal’s findings cannot be characterised as unreasonable, this court also notices that even if the figures of comparables were to be included, no adjustment would be permissible due to the fact that the margin of variation would be within the limits of the “Safe Harbour Provision” embodied in the Rules framed by the board in exercis .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... or the relevant year, with its AE. In its transfer pricing report, it included certain details and data of certain comparables. The TPO and thereafter the DRP included certain other comparables; the assessee s grievance with respect to the inclusion of the three comparables was accepted in the appeal by the impugned order. The comparables so excluded were M/s Accentia Technologies, iGate Global Co .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X