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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.
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