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        Case ID :
        Income Tax

        Determination of arm's length price (ALP) for international...

        Evaluating Comparable Companies for Arm's Length Price in International Deals: Key Criteria and Profit Indicators.

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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.
                                Determination of arm's length price (ALP) for international transactions, focusing on the selection of comparable companies. It excludes companies like Elofic Industries Ltd., WABCO TVS (India) Ltd., Brakes India Pvt. Ltd., Clutch Auto Ltd., ANG Industries Ltd., and Sundram Brake Linings Ltd. as functionally dissimilar or operating in different markets. It also discusses the inclusion/exclusion of Faiveley Transport Rail Technologies India Ltd., XLO India Ltd., and Rane Brake Lining Ltd. based on specific criteria. Additionally, it addresses the treatment of foreign exchange gains as operating income and the consideration of cash profit/operating income as a profit level indicator, citing relevant case laws. The summary covers the key issues related to comparable selection and ALP determination in a concise manner.
                                Note: It is a system-generated summary and is for quick reference only.
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