TP Adjustment - comparable selection - The Tribunal upheld the...

TP Adjustment - comparable selection - The Tribunal upheld the inclusion of HSIL Limited in the list of comparables, considering its core business activities in manufacturing and selling sanitaryware products. Despite some functional diversity, the Tribunal found the core activities sufficiently similar for comparison purposes. - The Tribunal directed the exclusion of Cera Sanitaryware Limited from the list of comparables. It noted that while the functions performed by Cera Sanitaryware Limited were similar to the Assessee's, the lack of proportionate revenue data for different activities made it unreliable for benchmarking purposes.

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