Related party transactions filter governed the inclusion of a comparable under TNMM benchmarking: the Tribunal noted from the annual financial statements that the company's related-party service income and other related-party income exceeded 25% of total revenue, which would fail the filter if the assessee's computation is verified correct. The matter was remitted to the TPO for verification, with a direction to exclude the company from the final comparables set if the 25% threshold is breached. Penalty initiation under section 270A was held premature and dismissed.
Related party transactions filter governed the inclusion of a comparable under TNMM benchmarking: the Tribunal noted from the annual financial statements that the company's related-party service income and other related-party income exceeded 25% of total revenue, which would fail the filter if the assessee's computation is verified correct. The matter was remitted to the TPO for verification, with a direction to exclude the company from the final comparables set if the 25% threshold is breached. Penalty initiation under section 270A was held premature and dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4790
Join Channel
TaxTMI 
