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Income Tax - Highlights / Catch Notes

Home Highlights November 2024 Year 2024 This

Transfer pricing adjustment rejected assessee's comparable ...


Transfer pricing adjustments questioned, comparables scrutiny ordered. Turnover filter misuse set aside.

Case Laws     Income Tax

November 27, 2024

Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply applicable filters, and include if comparable. Rejection of comparable solely on higher turnover set aside, directed consistent turnover filter application. Deferred receivables treated as international transaction, remanded to apply bank rate after allowing 60-day credit period. Partly allowed.

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