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        Case ID :
        Income Tax

        TP Adjustment - Comparable selection - determination of the...

        Tribunal Excludes Non-Comparable Companies from Arm's Length Price Analysis Due to Product Dissimilarity.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                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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