TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international...

TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international transactions - The appellant contested the inclusion of two companies, Roto Pumps Ltd. and Simmonds Marshall Ltd., as comparables due to product dissimilarity. The Appellate Tribunal upheld the exclusion of these comparables, emphasizing their dissimilar businesses compared to the appellant. Additionally, the Tribunal dismissed the appellant's objections regarding capacity utilization adjustment, PLI calculation, and treatment of foreign exchange gain/loss, as they became inconsequential post the exclusion of the disputed comparables. .....

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